Case Summary (G.R. No. 194945)
Facts of the Case
On the morning of September 25, 2005, an informant alerted SPO2 Dante Nagera about someone named "Alex" selling drugs in Barangay Payatas. In response, Nagera and his team, including PO1 Peggy Lynne Vargas designated as the poseur buyer, prepared for a buy-bust operation. At noon, Vargas approached the accused, Watamama, at his residence, posed as a buyer, and completed a transaction for P200 worth of shabu. Following the transaction, the buy-bust team arrested Watamama, recovering two marked bills as evidence.
Procedures Following Arrest
After the arrest, the confiscated shabu was brought to the police station where it was marked and logged by investigator Alex A. Jimenez. The evidence was then forwarded to the PNP Crime Laboratory for testing. Forensic chemist Leonard Jabonillo confirmed that the substance tested positive for methamphetamine hydrochloride (shabu).
Accused's Defense
Watamama claimed that his arrest was unlawful, asserting that he was apprehended without a warrant by individuals whom he alleged were civilian operatives. He stated that no evidence was found on his person during the police search and contended that upon his arrest, he was pressured to divulge the identity of a supposed drug supplier.
Trial Court Decision
The Regional Trial Court (RTC) convicted Watamama of illegal sale of shabu, sentencing him to life imprisonment and a fine of P500,000. On appeal, Watamama alleged that the prosecution did not adhere to the procedural requirements under Section 21(1) of Republic Act No. 9165, particularly regarding the marking and inventory of confiscated items.
Court of Appeals Findings
The Court of Appeals upheld the RTC decision, finding that the prosecution substantiated the chain of custody for the evidence and stated that the procedurally inadequate marking and inventory at the police station did not impede the prosecution's case. They noted that marking could occur at the apprehending team's nearest office if it preserved the integrity of the evidence.
Supreme Court's Analysis
The Supreme Court ruled that the prosecution failed to establish an unbroken chain of custody, which is essential for proving the identity and integrity of the narcotics. There was insufficient evidence detailing the handling of the seized shabu beyond its initial seizure by the arresting officer. The prosecution's reliance solely on Vargas’ testimony without corroborating
...continue readingCase Syllabus (G.R. No. 194945)
Background of the Case
- The case is an appeal from the March 5, 2010 Decision of the Court of Appeals (CA) in CA-G.R. CR HC No. 03295.
- The appeal concerns the conviction of Alex Watamama y Esil for violating Section 5 of Republic Act (R.A.) No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002.
- The Regional Trial Court (RTC) convicted the appellant, sentencing him to life imprisonment and a fine of P500,000.
Prosecution's Version of Events
- On September 25, 2005, at around 10:00 AM, an informant reported to SPO2 Dante Nagera about drug sales occurring in Barangay Payatas.
- SPO2 Nagera relayed the information to his superior, P/Supt. Gerardo Ratuita, who organized a buy-bust operation with a team of officers, including PO1 Vargas as the poseur buyer.
- At 12 noon, the team arrived at the designated location, where PO1 Vargas was introduced to the appellant as a shabu user.
- PO1 Vargas negotiated the purchase of P200 worth of shabu, handed over two marked P100 bills, and received a plastic sachet containing 0.18 grams of shabu from the appellant.
- Following the transaction, the buy-bust team arrested the appellant and recovered the marked bills.
Evidence Collection and Chain of Custody
- At the police station, the confiscated shabu was marked and turned over to investigator Alex A. Jimenez, who prepared an inventory receipt.
- The plastic sachet was sent to the PNP Crime Laboratory for examination, where forensic chemist Leonard Jabonillo confirmed it contained methylamphetamine hydrochloride (shabu)