Case Summary (G.R. No. 231008)
Summary of Facts
On September 14, 2011, Police Chief Inspector Mihilan Abu Payao was informed by a confidential source that an individual named Dennis was selling dangerous drugs. A buy-bust operation was organized, involving Police Officer (PO) 2 Joseph E. More as the poseur buyer and PO2 Alexander Saez as backup. During the operation at the food court of the mall, instead of Dennis, Seaeres and another individual, Federico Valencia, were introduced as the sellers. The duo facilitated a drug transaction, where Valencia exchanged a sachet of shabu for marked buy-bust money.
Court Proceedings
Following the buy-bust operation, PO2 More and the team arrested Seaeres and Valencia. The officers conducted inventory and prepared various documents, and the seized items tested positive for methamphetamine hydrochloride. The Regional Trial Court (RTC) subsequently found Seaeres guilty of selling illegal drugs, sentencing him to life imprisonment and a fine of PHP 500,000. Valencia was charged similarly but died prior to trial, leading to the dismissal of charges against him.
Appeals and Arguments
The Accused-Appellant, Seaeres, contested the RTC decision in the Court of Appeals (CA), focusing on multiple grounds, including the failure to establish a clear chain of custody for the drugs, inconsistencies in prosecution witnesses' testimonies, and procedural lapses regarding the inventory of seized items. He argued that the prosecution did not sufficiently prove his guilt beyond a reasonable doubt.
Legal Standards and Chain of Custody
Under Section 5, Article II of R.A. No. 9165, a conviction for illegal sale of drugs requires proof of (1) the identity of the buyer and seller, (2) the object of the sale, (3) the payment, and (4) the delivery of the drug. The integrity of the corpus delicti must be established, necessitating a reliable chain of custody. The court emphasized that the identity of the drugs must be proven without doubt, as articulated in precedent cases.
Compliance with Legal Protocol
Section 21 of R.A. No. 9165 mandates strict adherence to inventory and custody protocols during the seizure of illegal drugs. The absence of required witnesses—such as representatives from the media and Department of Justice—undermines the presumed integrity of the evidence unless justifiable grounds for this absence are established.
Ruling
The Supreme Court found that the
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Case Overview
- This case is an appeal by Federico Seaeres, Jr. y Ajero against the Decision of the Court of Appeals (CA) affirming his conviction for violating Section 5, Article II of Republic Act No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002.
- The initial conviction was rendered by the Regional Trial Court (RTC), Branch 70, Taguig City, on December 3, 2015.
- The appeal centers around the alleged failure of the prosecution to establish the chain of custody and the integrity of the seized dangerous drugs.
Factual Background
- On September 14, 2011, a confidential informant reported illegal drug activities to Police Chief Inspector Mihilan Abu Payao.
- A buy-bust operation was planned, with Police Officer (PO)2 Joseph E. More designated as the poseur-buyer.
- The operation took place at the Market! Market! Mall food court, where the informant introduced PO2 More to appellant Federico Seaeres, Jr. and Federico Valencia, Jr. as drug sellers.
- During the operation, PO2 More provided marked buy-bust money to Valencia, who then handed over a sachet of shabu (Methamphetamine Hydrochloride).
- The arrest was made immediately after the transaction, with both appellant and Valencia taken into custody.
Charges and Proceedings
- Two separate Informations were filed:
- Criminal Case No. 17690-D accused both Seaeres and Valencia of selling shabu.
- Criminal Case No. 17691-D charged Seaeres with possession of shabu.
- Both accused pleaded not guilty during their arraignment.
- The prosecution presented testimonies from police officers involved in the operation.
- Seaeres testified in his defense, claiming he was wrongly arrested and asserting the police had no evidence against him.
RTC Decision
- The RTC found Seaeres guilty beyond reasonable doubt of selling shabu and imposed a senten