Case Summary (G.R. No. 192284)
Factual Antecedents
On September 4, 2002, an amended information was filed, charging the petitioner with possessing 0.047 grams of shabu without legal authorization. The petitioner pleaded not guilty at his arraignment on December 9, 2002. During pre-trial, certain testimonies were waived, including that of Forensic Chemist P/Insp. Judycel Macapagal, as the defense acknowledged the handling and positive identification of the drug specimen by the police.
Version of the Prosecution
The prosecution's case was built upon the testimony of police officers who conducted an anti-criminality patrol on July 24, 2002, and observed the petitioner holding a plastic sachet containing shabu. Upon approaching the petitioner, the police confiscated the sachet and arrested him, subsequently marking the evidence and forwarding it to a forensic examination, which confirmed its identity as methamphetamine.
Version of the Defense
In contrast, the petitioner denied the allegations, claiming he was simply sitting outside his uncle's house when approached and arrested by the police without any explanation. He alleged extortion by the arresting officer, citing a demand for money for his release.
Ruling of the Regional Trial Court
The RTC concluded in its Amended Decision on August 29, 2008, that the prosecution convincingly established the petitioner's guilt beyond reasonable doubt, resulting in a sentence of 12 years and 1 day to 15 years of imprisonment and a fine of ₱300,000.
Ruling of the Court of Appeals
The Court of Appeals affirmed the RTC's conviction, maintaining that the prosecution sufficiently demonstrated the elements of illegal possession of prohibited drugs. The appellate court also upheld the presumption of regularity in police officers' duties and reinforced the integrity of the evidence based on the established chain of custody.
Issues Raised
The petitioner raised two primary issues on appeal: the alleged failure of the prosecution to prove the integrity and identity of the confiscated shabu and the assertion of irregularities in the actions of the apprehending officers.
The Court's Ruling
The Supreme Court found no merit in the petitioner’s assertions, emphasizing the repute of trial courts’ findings regarding credibility, which are afforded great respect if affirmed by an appellate court. The Court highlighted the established elements of illegal drug possession as met by the prosecution and dismissed the petitioner’s claims of improbability and inconsistencies in testimony as trifling and irrelevant to the core elements of the crime.
Chain of Custody and Procedural Compliance
The Court addressed the defense's concerns regarding t
...continue readingCase Syllabus (G.R. No. 192284)
Background of the Case
- The case is a Petition for Review on Certiorari regarding a decision by the Court of Appeals (CA) affirming the conviction of Alex Tionco y Ortega (petitioner) for violation of the Comprehensive Dangerous Drugs Act of 2002, specifically Section 11(3), Article II of Republic Act No. 9165.
- The case stems from an arrest on July 24, 2002, in Manila, where the petitioner was found in possession of a plastic sachet containing a dangerous drug, shabu (methamphetamine hydrochloride).
- The Regional Trial Court (RTC) of Manila, Branch 11, initially convicted the petitioner, which was subsequently upheld by the CA.
Factual Antecedents
- The petitioner was charged with illegal possession of a dangerous drug through an Amended Information dated September 4, 2002.
- The prosecution's evidence included the testimony of police officers who witnessed the petitioner holding a plastic sachet containing shabu.
- The defense claimed that the police had no right to arrest him and alleged extortion by the arresting officers.
Version of the Prosecution
- On the day of the incident, police officers conducted a routine patrol and observed the petitioner holding a sachet of white crystalline substance.
- After confirming the contents, the police confiscated the item and arrested the petitioner, who was informed of his rights.
- The plastic sachet was marked for identification and later tested positive for methamphetamine by a forensic chemist.