GR 213523; (March, 2021) (Digest)
G.R. No. 213523 , March 18, 2021
Michael Casilag y Arceo, Petitioner, vs. People of the Philippines, Respondent.
FACTS
An Information was filed accusing Michael Casilag of violating Section 11, Article II of R.A. No. 9165 for having in his possession two heat-sealed transparent sachets containing 0.02 gram of methamphetamine hydrochloride on April 16, 2010, in San Pedro, Laguna. The prosecution’s version, based on the testimonies of police officers, stated that during a surveillance operation in Barangay Cuyab, PO1 Freddie Ramos noticed two men seemingly engaged in a transaction, with one holding transparent plastic sachets. When approached, the men ran; Casilag was caught and the sachets were seized, marked, and later confirmed to contain shabu. The defense version claimed Casilag was at a friend’s house when two armed men entered, handcuffed him, and brought him to the police station without recovering anything from him. He later learned he was charged with drug possession. The Regional Trial Court convicted Casilag, a decision affirmed by the Court of Appeals. Casilag appealed to the Supreme Court, arguing non-compliance with Section 21 of R.A. No. 9165 and a broken chain of custody.
ISSUE
Whether the Regional Trial Court and the Court of Appeals erred in convicting Casilag of the crime charged.
RULING
The Supreme Court GRANTED the appeal, REVERSED and SET ASIDE the CA Decision, and ACQUITTED Michael Casilag on the ground of reasonable doubt. The Court found the prosecution’s version lacking in credibility and failing to prove guilt beyond reasonable doubt. Key inconsistencies and improbabilities were noted: the police operation lacked official coordination or records; the alleged transaction occurred openly in a narrow alley with the officers in plain view, yet the other suspect escaped; the marking of evidence was done solely by PO1 Ramos without immediate witness; and the required witnesses under Section 21 of R.A. No. 9165 were not present during inventory. The defense of frame-up was deemed plausible given the questionable police conduct. The Court emphasized the constitutional presumption of innocence and that the prosecution’s case must stand on its own merits. The Director of the Bureau of Corrections was ordered to secure Casilag’s immediate release, and the National Police Commission was directed to investigate the involved police officers.