Case Summary (G.R. No. 105830)
Sequence of Events
Joseph Sta. Cruz y Ilusorio faced charges related to illegal possession and sale of methamphetamine hydrochloride (shabu) on November 5, 2010. The charges included illegal possession of two plastic sachets containing shabu in Criminal Case No. 10-1979-MN and illegal sale of one sachet in Criminal Case No. 10-1980-MN for which he was apprehended during a buy-bust operation orchestrated by police operatives based on information from a confidential informant.
Prosecution's Case
The prosecution's case relied on testimonies from the poseur-buyer, Police Officer 2 Herbert Bagain, and the forensic chemist, Police Chief Inspector Stella Garciano. They presented evidence indicating that on November 5, 2010, the apprehension occurred after a successful buy-bust operation where the accused was caught selling shabu. The prosecution argued that the integrity and evidentiary value of the seized items were maintained throughout the chain of custody.
Defense's Position
The defense contested the prosecution’s claims, asserting that the accused was merely filling soil at his mother’s home when he was wrongfully apprehended by police. The defense characterized the arrest as unlawful, claiming that the accused did not possess nor sell illegal drugs.
Ruling of the Regional Trial Court (RTC)
In a Joint Decision rendered on October 30, 2017, the RTC found the accused guilty of both charges. The Court stated that possession of illegal drugs establishes prima facie evidence of animus possidendi, unless adequately rebutted by the accused. The penalties imposed included life imprisonment for the sale of shabu and a significant fine for possession.
Ruling of the Court of Appeals (CA)
The Court of Appeals upheld the RTC's decision on August 29, 2018, confirming that the prosecution had proven all elements of the crimes beyond reasonable doubt. It reiterated that the chain of custody for the seized drugs was effectively maintained, assuring the integrity of the evidence presented in court.
Supreme Court's Ruling
The Supreme Court ultimately reversed and set aside the CA's ruling, acquitting the accused. The Court underscored the importance of the chain of custody protocol as stipulated in Section 21 of R.A. No. 9165. It emphasized that the physical inventory and photographing of the seized drugs must occur immediately after confiscation and in the presence of essential witnesses.
Chain of Custody and Procedural Compliance
The Court highlighted failures in compliance with the statutory requirements including the absence of a Department of Justi
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Case Overview
- Case Reference: G.R. No. 244256
- Decision Date: November 25, 2019
- Deciding Body: Supreme Court of the Philippines, First Division
- Parties Involved: The People of the Philippines (Plaintiff-Appellee) vs. Joseph Sta. Cruz y Ilusorio (Accused-Appellant)
- Nature of the Case: Appeal against the conviction for illegal sale and possession of dangerous drugs under Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002.
Facts of the Case
- Charges:
- Criminal Case No. 10-1979-MN: Illegal possession of methamphetamine hydrochloride (shabu).
- Criminal Case No. 10-1980-MN: Illegal sale of shabu.
- Incident Date: November 5, 2010.
- Location: Malabon City, Metro Manila, Philippines.
- Evidence Gathered:
- In possession of accused-appellant: Two heat-sealed sachets containing shabu (0.03 grams and 0.02 grams respectively).
- Sale transaction with poseur-buyer involving a Php500.00 buy-bust operation.
- Arrest Procedure:
- Conducted by a buy-bust team led by P/C Insp. Leoben Ong.
- The arrest was made immediately after the sale, and additional sachets were found in the appellant's possession.
Prosecution's Version
- Witnesses:
- P/O2 Herbert Bagain, Jr. (poseur-buyer and arresting officer).
- P/C Insp. Stella S. Garciano (forensic chemist).
- Key Testimonies:
- Police received a tip about the accused's drug activities.
- The buy-bust operation was planned and executed the same day.
- The transaction was monitored, and the accused was apprehended immediately after handing over the drugs.
- The seized items were inventoried at the police station in the presence of a media representative.
Defense's Version
- Accused's Testimony:
- Denied involvement in drug activities.
- Claimed he was merely watching a game of mahjong when police offic