Case Summary (G.R. No. 175832)
Antecedent Facts
The prosecution charged Sanchez with unlawfully selling 0.02 grams of methylamphetamine hydrochloride, commonly known as shabu, during a buy-bust operation. During the trial, SPO2 Sevilla testified that he acted as the poseur buyer in the operation after being informed about a drug sale. The RTC based its decision primarily on Sevilla's credibility as a seasoned witness in drug cases, despite objections from the defense that questioned the legality of the arrest and the handling of the seized evidence.
Trial Proceedings
The RTC found Sanchez guilty and sentenced him to life imprisonment with a fine of P50,000. The prosecution presented various exhibits, including the laboratory reports confirming the presence of shabu, whereas the defense argued about the lack of proper chain of custody and questioned the credibility of the arresting officer's testimony.
Appellate Court Decision
Upon appeal to the Court of Appeals, Sanchez contended that the trial court erred in its judgment, emphasizing the reliance on SPO2 Sevilla's reputation rather than substantial evidence. The appellate court affirmed the RTC's decision, which prompted Sanchez's further appeal to the Supreme Court.
Court’s Ruling
The Supreme Court reversed the decision of the lower courts, arguing that the prosecution failed to prove Sanchez's guilt beyond reasonable doubt. The Court emphasized the significance of adhering to procedural requirements outlined in Section 21 of R.A. No. 9165 regarding the buy-bust operation. It found that the prosecution did not adequately demonstrate compliance with the mandated procedures concerning the inventory and custody of the seized drugs, which are critical to maintaining the integrity of evidence in drug-related cases.
Non-Compliance with Legal Procedures
The Court noted that proper inventory and photographic documentation of the seized drugs were not conducted in the presence of necessary representatives, including the accused. The Court underscored that mandatory procedures must be observed to prevent the abuse in drug apprehension operations, echoing concerns about the potential for evidence planting.
Chain of Custody Issues
Furthermore, the ruling highlighted the failures in establishing a clear chain of custody, which is essential for demonstrating that the evidence presented at trial is the same as that which was seized. The Supreme Court pointed out that the prosecution did not present a coheren
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Case Overview
- This case addresses the complexities involved in a buy-bust operation related to prohibited drugs, specifically the procedural difficulties faced by law enforcement and the prosecution.
- The appeal is from the September 11, 2006 Decision of the Court of Appeals, which upheld the Regional Trial Court's (RTC) ruling that found Salvador Sanchez y Espiritu guilty of violating Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002), resulting in a penalty of life imprisonment.
Antecedent Facts
- The appellant was charged with selling a dangerous drug (specifically, shabu) on April 6, 2003, in Quezon City.
- The prosecution's case rested on the testimony of a lone witness, SPO2 Levi Sevilla, alongside evidence collected during the operation.
- The defense claimed that the arrest was illegal, asserting that no drugs were found in the appellant's possession during the search.
Prosecution's Evidence
- SPO2 Sevilla testified that he received a tip from a confidential informant about a drug dealer in Quezon City.
- An entrapment team was organized, and a buy-bust operation was executed where Sevilla acted as the poseur buyer.
- Sevilla described how he received a plastic sachet containing shabu after handing over marked money to the accused, which he later identified in court.
Defense's Position
- The appellant denied the c