Case Summary (G.R. No. 225744)
Procedural History
The Regional Trial Court (RTC) of San Carlos City, Pangasinan, Branch 57, convicted the appellant for violating Section 5, Article II of Republic Act (RA) No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002. The conviction was affirmed by the Court of Appeals (CA) in its ruling dated September 4, 2015, which led to the appellant's appeal seeking reversal of the decision.
Prosecution’s Version of Events
On June 4, 2009, the Philippine Drug Enforcement Agency (PDEA) organized a buy-bust operation against appellant based on intelligence about his alleged drug dealing activities. Officer Jaime Clave acted as the poseur-buyer, purchasing shabu for P500.00. Upon completion of the transaction, the appellant was arrested, and the buy-bust money was recovered. The integrity of the seized drug was preserved through proper documentation by the arresting officers.
Defense’s Version of Events
The appellant denied the charges, claiming that the PDEA officers were at his residence searching for his parents and asserting that he was wrongfully accused. He stated that the PDEA officers interrogated family members and conducted a search without discovering illegal drugs, ultimately leading to his arrest due to familial connections with a barangay captain.
RTC’s Ruling
In its November 14, 2013 judgment, the RTC found the appellant guilty beyond reasonable doubt. The court emphasized the plausibility of the testimony provided by the PDEA officers and noted that the chain of custody of the seized drugs was maintained. The appellant was sentenced to life imprisonment and a fine of P500,000.00, while his co-accused, Teresita Baysic, was acquitted.
CA's Affirmation of RTC Decision
The CA's September 4, 2015 decision affirmed the RTC’s ruling, contending that procedural non-compliance with Section 21 of RA 9165 did not invalidate the prosecution's case, considering the integrity and evidentiary value of the seized drugs were preserved.
Key Legal Issues on Appeal
The primary argument in the appeal focused on the alleged failure of the prosecution to establish a proper chain of custody for the seized shabu. The appellant contended that the police failed to comply with mandatory requirements during the buy-bust operation, specifically the absence of representatives from the media and the Department of Justice (DOJ) during the inventory and documentation of the seized items.
Legal Standards for Chain of Custody
Under Section 21 of RA 9165, certain procedural safeguards are mandated during the seizure of illegal drugs, requiring physical inventory and photo documentation in the presence of specified witnesses. The jurisprudence dictates that unless the absence of these witnesses is justified, non-compliance may jeopardize the prosecution's case by creating reasonable doubt regarding the integri
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Case Background
- This case involves an appeal by Jonathan Vistro y Baysic (appellant) against a decision by the Court of Appeals affirming his conviction for violating Section 5, Article II of Republic Act (RA) No. 9165, the Comprehensive Dangerous Drugs Act of 2002.
- The Regional Trial Court (RTC) of San Carlos City, Pangasinan, had initially found him guilty of selling shabu (Methamphetamine Hydrochloride) during a buy-bust operation on June 4, 2009.
Accusatory Allegations
- The Information against the appellant alleged that he, in conspiracy with others, unlawfully sold one heat-sealed plastic sachet containing 0.01 grams of shabu to a poseur-buyer without any license to do so.
- The incident occurred in the afternoon at Acosta St., Poblacion, Urbiztondo, Pangasinan.
Procedural History
- Upon being arraigned, the appellant pleaded "not guilty."
- Following the pre-trial conference, the trial commenced, with the prosecution and defense presenting their respective cases.
Version of the Prosecution
- The prosecution's case was built around a buy-bust operation conducted by the Philippine Drug Enforcement Agency (PDEA) based on intelligence reports.
- Intelligence Officer Jaime Clave (IO Clave) posed as a buyer, receiving P500.00 as buy-bust money, while other officers provided perimeter security.
- The operation