Case Summary (G.R. No. 113003)
Background of the Case
Eduardo Yepes was charged with the illegal sale of a dangerous drug, specifically methylamphetamine hydrochloride, commonly known as "shabu." This accusation stemmed from a buy-bust operation conducted by the Samar Provincial Police Office on July 29, 2004. During the operation, PO1 Ervin A. AriAo acted as the poseur-buyer and exchanged marked money for what was believed to be shabu, leading to Yepes's arrest.
Proceedings and Evidence
At trial, the prosecution presented several witnesses, including police officers involved in the operation. PO1 AriAo testified that he initiated the buy-bust operation after being authorized by Police Inspector Carlos G. Vencio. He alleged that he purchased shabu from Yepes, who was identified only through a police asset. Other officers, including PO2 Lapura and SPO4 dela Cruz, corroborated the buy-bust details, although they were not directly involved in the transaction.
Accused-Appellant's Defense
Eduardo Yepes maintained his innocence throughout the proceedings, providing an alibi that he was at a different location at the time of the alleged crime. He claimed that the alleged operatives, rather than apprehending him for drug-related offenses, attempted to plant shabu on him. Yepes denied ever selling or having shabu in his possession.
Trial Court Ruling
On December 19, 2008, the RTC convicted Yepes of illegal drug sale and imposed a penalty of life imprisonment and a fine of five hundred thousand pesos. However, he was acquitted of illegal possession due to insufficient evidence.
Appeal to the Court of Appeals
Yepes sought reconsideration, offering a joint affidavit from four individuals asserting that the buy-bust operation did not occur. The RTC denied this request, affirming its initial ruling. The Court of Appeals subsequently upheld the RTC's decision, affirming his conviction while modifying the specifics of the ruling.
Supreme Court Review and Findings
Upon appeal to the Supreme Court, it was determined that the prosecution failed to prove the case beyond a reasonable doubt. Critical deficiencies in the procedural conduct of the police during the buy-bust operation were identified. Key points included:
- Lack of presentation of the police asset, whose testimony was pivotal for the identification of Yepes as the drug seller.
- Inconsistencies in the testimonies of the police officers concerning the number of sachets seized and the handling of evidence, suggesting a breach in the chain of custody.
- Absence of adherence to the
Case Syllabus (G.R. No. 113003)
Case Overview
- This case involves the appeal of Eduardo Yepes against the Decision of the Court of Appeals which affirmed his conviction for selling illegal drugs under the Comprehensive Dangerous Drugs Act of 2002 (R.A. No. 9165).
- The Regional Trial Court (RTC) had previously sentenced him to life imprisonment for selling methamphetamine hydrochloride, commonly known as shabu.
Factual Background
- On July 29, 2004, a buy-bust operation was conducted by the Samar Provincial Police at Purok 6, Barangay Guindapunan, Catbalogan City.
- The accused-appellant was alleged to have sold one heat-sealed plastic bag containing shabu to PO1 Ervin AriAo, who acted as the poseur buyer.
- The operation was authorized by Police Inspector Carlos G. Vencio, and the transaction was backed by marked money consisting of two PHP 100 bills.
Trial Proceedings
- During the trial, several police officers testified regarding the operation and the evidence recovered.
- The key witnesses included:
- PO2 Ervin AriAo: Described the buy-bust operation and the exchange of money for the alleged drugs.
- PO2 Lapura: Confirmed he witnessed the transaction but stated he could not see the drug due to distance.
- SPO4 dela Cruz: Conducted a field test on the seized substance and concluded it was shabu.
- PO3 Ilagan: Testified as the evidence custodian who received the drugs at the police station.
Accused-Appellant's Defense
- Eduardo Yepes denied