Case Summary (G.R. No. 227187)
Charges and Plea
Sevilla faced two separate charges under Republic Act No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002. In Criminal Case No. CrC 211-2010, he was charged with the illegal sale of dangerous drugs (specifically, marijuana), and in Criminal Case No. CrC 212-2010, he faced charges of illegal possession of dangerous drugs. Upon arraignment on July 30, 2010, Sevilla pleaded not guilty.
Prosecution's Case
The prosecution's narrative was supported by multiple witnesses, including law enforcement officials involved in the buy-bust operation. They testified that a confidential informant informed them about Sevilla selling marijuana. Following instructions, an operation was carried out where an undercover officer (IO1 Julius A. Magdadaro) posed as a buyer. Upon the successful transaction where marijuana was exchanged for marked money, Sevilla was arrested, leading to the seizure of marijuana and the marked bill.
Defense's Argument
The defense presented Sevilla's testimony, wherein he claimed that he was wrongfully arrested without basis, denying any involvement in selling marijuana. He described being confronted by a group of about ten individuals who accused him of selling drugs as he entered his house, claiming that he was later taken to the police station where photographs were taken with marijuana laid in front of him.
Regional Trial Court's Ruling
The RTC found Sevilla guilty on December 1, 2014. It determined that the defense of denial was weak and insufficient to favorably impact the credibility of the prosecution's case. The court imposed a penalty of life imprisonment and a ₱500,000 fine for the sale of marijuana and a sentence of 12 years and one day to 13 years imprisonment and a ₱300,000 fine for possession.
Court of Appeals Review
Sevilla appealed his conviction to the CA, arguing that the prosecution failed to adhere to the procedural requirements under Section 21 of RA 9165, affecting the chain of custody of the seized drugs. The CA upheld the RTC's ruling on July 29, 2016, affirming that the prosecution sufficiently proved the chain of custody and upheld the presumption of regularity in the actions of law enforcement.
Supreme Court's Conclusion
The Supreme Court dismissed Sevilla's appeal, noting that the standards for proving illegal sale and possession of dangerous drugs were satisfactorily met. The Court highlighted the necessity of esta
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Case Background
- The case involves an appeal filed by Eric L. Sevilla (appellant) contesting the July 29, 2016 Decision of the Court of Appeals (CA).
- The CA affirmed the December 1, 2014 Decision of the Regional Trial Court (RTC), Branch 34, Panabo City.
- Appellant was found guilty beyond reasonable doubt of violating Sections 5 (illegal sale of dangerous drugs) and 11 (illegal possession of dangerous drugs), Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
Charges Against the Appellant
- Criminal Case No. CrC 211-2010:
- Date: May 26, 2010
- Location: Panabo City, Davao, Philippines
- Charge: Illegal sale of two packs of dried marijuana leaves to poseur-buyer IO1 Julius A. Magdadaro for Php100.00.
- Criminal Case No. CrC 212-2010:
- Date: May 26, 2010
- Location: Panabo City, Davao, Philippines
- Charge: Illegal possession of ten packs of marijuana leaves weighing 55.8873 grams.
Proceedings and Evidence
- Appellant pleaded not guilty during arraignment on July 30, 2010.
- The prosecution presented several witnesses, including police officers involved in the buy-bust operation, establishing the details of the case.
Prosecution's Narrative
- On May 26, 2010, Agent Caludito CaAada received a tip regarding appel