Tuesday, June 20, 2017

Case Digest: People vs. Del Monte

G.R. No. 179940, April 23, 2008
People vs. NORBERTO DEL MONTE Y GAPAY alias “OBET”

Facts:
Accused-appellant questioned his conviction, contending that the evidence against him should have been rendered inadmissible for failure to comply with Section 21 of RA 9165.

Ruling:
Accused-appellants claim that police failed to take pictures of him with the evidence and that the police, who had initial custody, failed to conduct physical inventory was raised only during appeal.

The court held that it is already late for accused-appellant to do this.

The law excuses non-compliance under justifiable grounds.  However, whatever justifiable grounds may excuse the police officers involved in the buy-bust operation in this case from complying with Section 21 will remain unknown, because appellant did not question during trial the safekeeping of the items seized from him.  Indeed, the police officers' alleged violations of Sections 21 and 86 of Republic Act No. 9165 were not raised before the trial court but were instead raised for the first time on appeal.  In no instance did appellant least intimate at the trial court that there were lapses in the safekeeping of seized items that affected their integrity and evidentiary value.  Objection to evidence cannot be raised for the first time on appeal; when a party desires the court to reject the evidence offered, he must so state in the form of objection.  Without such objection he cannot raise the question for the first time on appeal. 

The Court also added that, non-compliance with Section 21 of said law, particularly the making of the inventory and the photographing of the drugs confiscated and/or seized, will not render the drugs inadmissible in evidence.  

Afterall, all the elements necessary to prosecute sale of illegal drugs had been established. The prosecution clearly showed that the sale of the drugs actually happened and that the shabu subject of the sale was brought and identified in court. 


The court sustained accused-appellant’s conviction.

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