Case Summary (G.R. No. 212626)
Charges and Initial Proceedings
An Information was filed against Ternida alleging that he sold 0.0402 grams of methamphetamine hydrochloride, commonly known as "shabu." The substance was reportedly sold to a police operatives' poseur-buyer using marked money. Ternida pleaded not guilty upon arraignment, and the trial proceeded through pre-trial and merits hearings.
Prosecution's Version of Events
The prosecution presented its case stating that on November 12, 2009, a confidential informant alerted the San Fernando City Police about Ternida’s impending drug sale. A buy-bust operation was organized, leading to Ternida's arrest on November 17, 2009. The police claimed that they seized a heat-sealed plastic sachet containing shabu during the transaction, which was later subjected to forensic examination confirming the identity of the substance.
Defense's Claims
Ternida contested the buy-bust operation's legitimacy, asserting that he was simply arrested without any actual drug sale occurring. His argument hinged on the lack of photographic evidence of the seized drugs and alleged inconsistencies in the testimonies of the arresting officers regarding the presence of witnesses during the operation. Ternida also pointed out that there was no coordination with the Philippine Drug Enforcement Agency (PDEA) prior to his arrest, contrary to required protocols.
Trial Court's Decision
On July 6, 2011, the Regional Trial Court found Ternida guilty beyond a reasonable doubt and sentenced him to life imprisonment and a fine of Php500,000. Ternida subsequently appealed the decision.
Appellate Arguments
Ternida contended that the prosecution did not adequately preserve the identity and integrity of the corpus delicti, particularly highlighting procedural failures such as the absence of evidence indicating the drugs were photographed upon seizure. The defense maintained that essential witnesses were not presented, and the prosecution failed to establish a proper chain of custody.
Court of Appeals Ruling
The Court of Appeals upheld the Regional Trial Court's decision on October 30, 2013, stating that despite lapses in procedure, the elements of the crime were met.
Supreme Court's Analysis
The Supreme Court reviewed the circumstances surrounding Ternida's conviction, focusing on the prosecution's failure to comply with the chain of custody requirements outlined in Article II, Section 21 of Republic Act No. 9165. It emphasized that immediate inventory and photography of seized items are mandated to ensure evidence integrity and address doubt regarding the identity of the controlled substance.
Failure to Establish Compliance
The prosecution could not provide justification for not photographing the seized ite
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Case Overview
- Court: Supreme Court of the Philippines
- Date: June 03, 2019
- G.R. No.: 212626
- Decision Writer: Justice Leonen
- Parties: People of the Philippines (Plaintiff-Appellee) vs. Rolando Ternida y Munar (Accused-Appellant)
Background of the Case
- The case involves the conviction of Rolando Ternida y Munar for the illegal sale of dangerous drugs, specifically, 0.0402 grams of methamphetamine hydrochloride (shabu).
- The prosecution was based on a buy-bust operation conducted by the San Fernando City Police on November 17, 2009.
- Ternida was accused of selling shabu to PO2 Ricardo Annague, who acted as a poseur buyer.
Facts of the Case
- A confidential informant alerted the police about Ternida's planned drug transaction five days prior to the operation.
- The buy-bust team consisted of several officers, including PO2 Annague as the poseur buyer and PO3 Batnag as the backup.
- During the operation, Ternida handed over one heat-sealed plastic sachet containing the substance in exchange for a ₱1,000 bill marked as buy-bust money.
- Ternida was arrested immediately after the transaction, and a Certificate of Inventory was prepared.
Trial Proceedings
- Ternida denied the occurrence of the buy-bust operation, claiming he was arrested without cause while walking to a restaurant.
- He contended that the police officers took his belongings, including a cell phone and cash, and photographed him beside the plastic sachet after his arrest.
- The Regional Trial Court (RTC) found Ternida guilty beyond reasonable doubt and sentenced him to life imprisonment and a fine of ₱500,000.
Issues Raised on Appeal
- Ternida appealed the RTC's decision, arguing the prosecution failed to preserve the integrity and identit