Case Summary (G.R. No. 244545)
Factual Background
The Laoag City Police conducted a buy-bust operation following a tip-off about Reyes selling drugs. PO1 Irving Lorenzo acted as the poseur-buyer, and upon meeting Reyes at his apartment, a pre-arranged transaction unfolded where Reyes allegedly sold a sachet of shabu for P1,000. After the transaction, Reyes was arrested, and further illegal drugs were recovered from him. The police also sought and obtained the presence of Barangay Kagawad Helen Bulaun for the inventory of the seized items, which were later tested and confirmed to contain shabu.
Charges Filed
Reyes faced two separate charges before the Regional Trial Court (RTC):
- Criminal Case No. 17067-14 – Illegal Sale of Dangerous Drugs for selling shabu without any authority, with a weight of 0.2025 grams.
- Criminal Case No. 17068-14 – Illegal Possession of Dangerous Drugs for possessing three sachets of shabu weighing an aggregate of 2.3158 grams.
Defense Argument
Reyes denied the allegations, asserting that he was not selling drugs and that the police misconducted themselves during the arrest. He contended that he was apprehended without proper process and that items related to the case were not recovered from him during a legitimate search.
RTC Decision
On March 7, 2017, the RTC found Reyes guilty beyond reasonable doubt. The court imposed a life sentence for the illegal sale and a prison term from thirteen to fifteen years for illegal possession, both accompanied by significant fines. The RTC emphasized the prosecution's credibility regarding the buy-bust operation.
Appeal to the Court of Appeals
Reyes appealed to the Court of Appeals (CA), which upheld the RTC's decision on July 20, 2018, affirming the findings of the lower court while modifying the fine for the illegal possession charge.
Grounds for Review
Upon further review by the Supreme Court, Reyes maintained that the prosecution failed to prove the chain of custody of the evidence, which is critical in illegal drug cases. The prosecution is required to demonstrate an unbroken chain of custody from seizure to court presentation.
Ruling of the Supreme Court
The Supreme Court acquitted Reyes, emphasizing the importance of maintaining the integrity of the chain of custody as outlined in Section 21 of Republic Act No. 9165. The Court noted that there was a significant breakdown in the chain of custody, particularly the lack of insulating witne
...continue readingCase Syllabus (G.R. No. 244545)
Case Background
- The case involves the conviction of Franklin Reyes for Illegal Sale and Possession of Dangerous Drugs, stemming from activities on January 28, 2016.
- The proceedings were initiated following a buy-bust operation conducted by the Laoag City Police Station based on information received from a police asset regarding Reyes's alleged drug dealing activities.
Buy-Bust Operation
- A police operation was organized after a tip-off about Reyes, who allegedly sold illegal drugs along Magat Salamat Street.
- PO1 Irving Lorenzo was designated as the poseur-buyer, supported by PO1 Jay Joemar Corpuz and other officers.
- The police asset contacted Reyes, leading to a meeting at his apartment where the buy-bust transpired.
- Reyes accepted a marked P1,000.00 bill in exchange for a plastic sachet containing methamphetamine hydrochloride, known as shabu.
- Upon completion of the transaction, Reyes was arrested, and additional illegal substances were found during a frisk search.
Charges and Trial
- Reyes was charged with two separate counts:
- Criminal Case No. 17067-14: For the illegal sale of shabu (0.2025 grams).
- Criminal Case No. 17068-14: For illegal possession of shabu (2.3158 grams).
- During the trial, Reyes denied the acc