People v. Dejos
REITERATIONFacts
The Antecedents: The accused-appellant, Neil Dejos y Pinili, was charged with Illegal Sale of Dangerous Drugs under Section 5, Article II of Republic Act No. (RA) 9165. The prosecution alleged that on July 17, 2012, operatives conducted a buy-bust operation where they recovered seven sachets of shabu from the accused-appellant. Subsequently, an entrapment was conducted against May Flor Saraña y Buncalan, from whom three more sachets of shabu were recovered. The seized items were inventoried and photographed in the presence of the accused-appellant and required witnesses. Laboratory examination confirmed the contents to be methamphetamine hydrochloride. Procedural History: The Regional Trial Court (RTC) found the accused-appellant guilty of Illegal Possession of Dangerous Drugs under Section 11, Article II of RA 9165, not Illegal Sale, sentencing him to life imprisonment and a fine of P400,000.00. The RTC found that while the elements of illegal sale were not fully established, there was glaring evidence of possession, and the accused-appellant failed to show authority to possess the drugs. The Court of Appeals (CA) affirmed the RTC Decision. The Petition: The accused-appellant appealed to the Supreme Court, maintaining that there was no moral certainty on the identity and integrity of the corpus delicti and that his warrantless arrest was invalid.
Issue(s)
Whether the identity and integrity of the corpus delicti were established with moral certainty. Whether the accused-appellant's warrantless arrest was valid. Whether the accused-appellant is guilty of Illegal Possession of Dangerous Drugs under Section 11, Article II of RA 9165.
Ruling
The appeal is without merit. The Court affirmed the Decision of the Court of Appeals, finding the accused-appellant guilty beyond reasonable doubt of Illegal Possession of Dangerous Drugs under Section 11, Article II of RA 9165, and sentencing him to suffer the penalty of life imprisonment and a fine of P400,000.00.
Ratio Decidendi
On the identity and integrity of the corpus delicti and the chain of custody: The Court held that the prosecution sufficiently complied with the chain of custody rule under Section 21, Article II of RA 9165. The marking, physical inventory, and photography of the seized items were conducted immediately after seizure and confiscation. The inventory and photography were done in the presence of the accused-appellant and the required witnesses, namely, a media representative, a DOJ representative, and a Barangay Captain. The seized items were then properly turned over to the crime laboratory for examination, and subsequently presented in court. There were no lapses in the disposition and handling of the seized items that would cast doubt on their integrity and evidentiary value. The prosecution proved beyond reasonable doubt that the accused-appellant illegally possessed the shabu. On the validity of the warrantless arrest: The Court respected the findings of the lower courts that the accused-appellant was caught in flagrante delicto possessing shabu following a buy-bust operation. The testimonies of the prosecution witnesses, who are police officers presumed to have performed their duties regularly, were found credible. The accused-appellant's defense of denial and frame-up was uncorroborated and thus failed to overcome the presumption of regularity in the performance of official duties. On the conviction for Illegal Possession of Dangerous Drugs: The Court affirmed the RTC and CA's finding that the accused-appellant committed Illegal Possession of Dangerous Drugs. While the elements of illegal sale were not fully established because the accused-appellant was arrested before receiving the marked money, possession of dangerous drugs is necessarily included in the sale of prohibited drugs. The elements of illegal possession were met: (a) the accused was in possession of a prohibited drug; (b) such possession was not authorized by law; and (c) the accused freely and consciously possessed the drug. The accused-appellant failed to present any satisfactory explanation for his possession of the dangerous drugs, thus establishing prima facie evidence of knowledge and intent to possess.
Main Doctrine
The prosecution complied with the chain of custody rule, and thus, the integrity and evidentiary value of the corpus delicti have been properly preserved, proving beyond reasonable doubt the guilt of the accused for illegal possession of dangerous drugs.