People v. Dadang
REITERATIONFacts
The Antecedents: The case stemmed from three Informations charging accused-appellant Quisar Arances Dadang (Dadang) with violations of Sections 5, 11, and 12 of Republic Act (R.A.) No. 9165. The prosecution presented evidence that on August 7, 2015, the Cagayan de Oro City Anti-Illegal Drug Task Force (CAIDTF), in coordination with the Philippine Drug Enforcement Agency (PDEA), planned a buy-bust operation based on information that a certain "Manoy," later identified as Dadang, was selling illegal drugs. Police Officer (PO) 3 Cyrus Baillo acted as the poseur-buyer, with Senior Police Officer (SPO) 1 Rene Destura as back-up. A P1,000.00 marked bill was prepared. The team proceeded to Jerggy's Inn, where PO3 Baillo and a confidential informant (CI) entered Dadang's room. Inside, PO3 Baillo observed drug paraphernalia. The CI requested to buy illegal drugs, handing over the marked money. Dadang received the money and gave a sachet containing white crystalline substance to the CI, who then passed it to PO3 Baillo. This was the pre-arranged signal. The team entered the room, apprehended Dadang, and informed him of his constitutional rights. A body search yielded another plastic sachet of white crystalline substance from Dadang's left pocket, along with the marked money. At the crime scene, an inventory and marking of seized items were conducted in the presence of Dadang, a Barangay Kagawad, and a media representative. Dadang refused to sign the inventory receipts. The seized items, including two sachets of suspected shabu and drug paraphernalia, were brought to the crime laboratory. Chemistry Report No. D-584-2015 confirmed the presence of methamphetamine hydrochloride (shabu) in both sachets and the paraphernalia. Procedural History: The Regional Trial Court (RTC), Branch 23, Cagayan de Oro City, in its Decision dated March 28, 2017, found Dadang guilty beyond reasonable doubt of illegal sale (Criminal Case No. CR-DRG-2015-416), illegal possession of dangerous drugs (Criminal Case No. CR-DRG-2015-417), and illegal possession of drug paraphernalia (Criminal Case No. CR-DRG-2015-418), imposing penalties for each offense. Dadang appealed his conviction to the Court of Appeals-Cagayan de Oro City. The Court of Appeals, in its Decision dated August 30, 2018, affirmed the RTC ruling in toto, finding that all elements for the crimes were established and the chain of custody was unbroken. The Petition: Dadang appealed to the Supreme Court, seeking to overturn his conviction.
Issue(s)
Whether the guilt of the accused-appellant for illegal sale, illegal possession of dangerous drugs, and illegal possession of drug paraphernalia was established beyond reasonable doubt. Whether there was a proper chain of custody over the seized dangerous drugs and paraphernalia. Whether the penalties imposed by the trial court and affirmed by the Court of Appeals were in accordance with law.
Ruling
The appeal is dismissed. The Supreme Court affirms the conviction of Quisar Arances Dadang for illegal sale, illegal possession of dangerous drugs, and illegal possession of drug paraphernalia, with modifications to the imposed penalties.
Ratio Decidendi
On the guilt for illegal sale, illegal possession of dangerous drugs, and illegal possession of drug paraphernalia: The Court held that all the elements for the crimes charged were present. For illegal sale, the transaction took place, the corpus delicti (shabu) was presented, and the buyer and seller were identified. A buy-bust operation was conducted, resulting in the sale of 0.1982 gram of shabu. Subsequently, another sachet of shabu weighing 0.5449 gram was recovered from Dadang's possession during a search incidental to his arrest, establishing illegal possession. Furthermore, drug paraphernalia, specifically a folded aluminum foil and an improvised glass pipe, were found in his possession without authority, satisfying the elements of illegal possession of drug paraphernalia. The Court gave high respect to the findings of fact of the trial court, as affirmed by the Court of Appeals, finding no reason to disregard them. On the chain of custody: The Court found that the buy-bust team sufficiently complied with the chain of custody rule under Section 21 of R.A. No. 9165, as amended by R.A. No. 10640. The apprehending officers immediately marked the seized items at the place of arrest in the presence of the accused. An inventory and photograph of the seized items were conducted in the presence of the accused, a barangay kagawad, and a media representative. The items were then brought to the crime laboratory for examination, and the forensic chemist identified the substances as shabu. The seized items were subsequently deposited with the crime laboratory evidence custodian for safekeeping until presented in court. The Court concluded that the integrity and evidentiary value of the corpus delicti were preserved. On the penalties imposed: The Court affirmed the penalty for illegal sale of dangerous drugs, which is life imprisonment and a fine of P500,000.00, in accordance with Section 5, Article II of R.A. No. 9165, as amended by R.A. No. 9346. For illegal possession of dangerous drugs (0.5449 gram of shabu), the Court modified the penalty to an indeterminate period of twelve (12) years and one (1) day, as minimum, to fourteen (14) years, as maximum, and a fine of P300,000.00, applying the Indeterminate Sentence Law and recent jurisprudence. Similarly, for illegal possession of drug paraphernalia, the penalty was modified to an indeterminate period of six (6) months and one (1) day, as minimum, to two (2) years, as maximum, and a fine of P10,000.00, also in accordance with the Indeterminate Sentence Law and prevailing jurisprudence.
Main Doctrine
The prosecution established beyond reasonable doubt the guilt of the accused for illegal sale, illegal possession of dangerous drugs, and illegal possession of drug paraphernalia. The chain of custody rule was sufficiently complied with, preserving the integrity and evidentiary value of the seized items. Penalties imposed were affirmed with modifications based on prevailing jurisprudence and the Indeterminate Sentence Law.