Tuesday, June 20, 2017

Case digest: People vs. Alcuizar

G.R. No 189980
People vs. Alberto Bacus Alcuizar
April 6, 2011

Facts:

Appellant Alcuizar was charged with violation of Sections 5 (illegal sale), 6 (maintaining a drug den), 11 (illegal possession) and 12 (illegal possession of dangerous drug paraphernalia) of Republic Act No. 9165 a buy bust operation and a search on his home by virtue of a warrant led by a SPO1 Agadier.

Present during the search were appellant, appellant’s sister-in-law, one barangay captain, one barangay tanod, and several photographers.

In the RTC, appellant was acquitted in all charges except for his violation of Section 11 or illegal possession of dangerous drug as evidenced by the stic packs of shabu found in his room.

Appellant questions the veracity of the seized item by virtue of the Chain of Custody rule. Appellant cites the failure of the police in marking the evidence immediately after purportedly taking it from him as well as the failure of the police officers to give or leave a copy of the inventory receipt upon the accused or any of his family members.

CA finds the appellant’s contention meritorious.

Ruling:

The gaps in the chain of custody (i.e the transfer of custody, control and custody of the shabu, and the marking of the shabu) affected the identity of the corpus delicti.

To successfully prosecute a case of illegal possession of dangerous drugs, the following elements must be established: (1) the accused is in possession of an item or object which is identified to be a prohibited drug; (2) such possession is not authorized by law; and (3) the accused freely and consciously possessed the said drug.


The doubt created by the gaps in the custody, the testimonies and the lack of witnesses to prove that the prohibited drugs were found in appellant’s home constrained the Court to acquit appellant.

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