PEOPLE v. PUYAT MACAPUNDAG Y LABAO

FACTS:

The accused, Puyat Macapundag, was charged with violating Sections 5 and 11, Article II of Republic Act No. 9165, for selling and delivering Ephedrine without the necessary license or prescription, as well as possessing three heat-sealed transparent plastic sachets containing Ephedrine. The prosecution conducted a buy-bust operation after receiving information that Macapundag was selling shabu. PO3 George Ardedon acted as the poseur-buyer, while SPO1 Arnel Victoriano and PO2 Jeffred Pacis acted as back-up officers. Macapundag allegedly sold a sachet of Ephedrine to PO3 Ardedon and was subsequently arrested. The seized items were turned over to the police station and were later found to test positive for Ephedrine. Macapundag denied the charges, claiming that he was arrested on a different date.

The Regional Trial Court (RTC) found Macapundag guilty of violating Sections 5 and 11, Article II of RA 9165. The Court of Appeals (CA) affirmed the RTC's decision, concluding that the prosecution had proven beyond reasonable doubt that Macapundag unlawfully sold and possessed dangerous drugs. The CA also determined that the integrity of the seized drugs was preserved and the chain of custody was not compromised.

ISSUES:

  1. Whether or not Macapundag is guilty beyond reasonable doubt of violating Sections 5 and 11, Article II of RA 9165.

  2. Whether or not the prosecution was able to establish an unbroken chain of custody over the seized items.

RULING:

  1. Macapundag is guilty beyond reasonable doubt of violating Sections 5 and 11, Article II of RA 9165.

  2. The prosecution was able to establish an unbroken chain of custody over the seized items.

PRINCIPLES:

  • The illegal sale and illegal possession of dangerous drugs are penalized under Sections 5 and 11, Article II of Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002.

  • The prosecution has the burden of proving the guilt of the accused beyond reasonable doubt.

  • The integrity of the seized drugs must be duly preserved and the chain of custody must be established to ensure the admissibility of the evidence in court.