Case Digest: People vs.Ted Miguel Batoon and Melchor Miguel Batoon

G.R. No 184599

People vs.Ted Miguel Batoon and Melchor Miguel Batoon

November 24, 2010

Facts:

Accused-appellants Teddy Batoon and Melchor Batoon were found guilty of violating Sections 5 and 11 of Republic Act No. (RA) 9165 or the Comprehensive Dangerous Drugs Act of 2002 after they sold a sachet to a poseur-buyer in a buy-operation and after 3 more sachets were found in their possession.

Teddy and Melchor appealed the decision, questioning the chain of custody over the alleged confiscated prohibited drugs and Melchor’s conviction for illegal possession of shabu. 

Ruling:

In a prosecution for illegal sale of dangerous drugs, the following elements must be established: (1) proof that the transaction or sale took place; and (2) the presentation in court of the corpus delicti or the illicit drug as evidence.

The Court held that the buy-bust operation was valid and that there had been no showing in the records that the chain of custody was broken.

For conviction of illegal possession of a prohibited drug to lie, the following elements must be established: (1) the accused was in possession of an item or an object identified to be a prohibited or regulated drug; (2) such possession is not authorized by law; and (3) the accused was freely and consciously aware of being in possession of the drug. Although the three sachets containing shabu were found solely in the possession of Teddy, it was evident that Melchor had knowledge of its existence. Records regarding the transaction between the poseur-buyer, Teddy and melchor showed that the accused-appellants conspired in the illegal-business of drugs.

Proof beyond reasonable doubt against accused-appellants were held to have been successfully adduced. 

Categories: 2010, case digest, CRIMINAL LAW, Drugs case, Gr 184559, People vs. Batoon, People vs.Ted Miguel Batoon and Melchor Miguel Batoon, RA 9165, SPECIAL CRIMINAL LAW