GR 191064; (October, 2010) (Digest)
G.R. No. 191064 ; October 20, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ROLANDO ARANETA y ABELLA @ BOTONG and MARILOU SANTOS y TANTAY @ MALOU, Accused-Appellants.
FACTS
On July 5, 2002, a police team conducted a buy-bust operation in Pasig City based on a confidential informant’s tip regarding appellants Rolando Araneta and Marilou Santos. PO2 Danilo Damasco acted as poseur-buyer, using a marked P100 bill. At the target location, the informant introduced PO2 Damasco to Santos, who asked, “Magkano?” Upon receiving the marked money, Santos handed it to Araneta, who then gave her a plastic sachet containing shabu, which she passed to PO2 Damasco. After the pre-arranged signal, the team arrested the appellants. A search of Araneta yielded the marked bill, eight more sachets of shabu, and one sachet of marijuana. The seized items were marked and later confirmed by forensic examination to be dangerous drugs.
The appellants presented a different version, claiming they were sleeping when police officers forcibly entered their home without a warrant, arrested them, and planted the evidence. They alleged the operation was a frame-up and denied any involvement in drug trafficking.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of the appellants for violations of Sections 5 and 11, Article II of Republic Act No. 9165 .
RULING
The Supreme Court affirmed the conviction. The prosecution successfully established all elements of illegal sale and possession of dangerous drugs. The detailed testimony of PO2 Damasco clearly outlined the buy-bust transaction—from the initial offer, payment of the marked money, to the consummation of the sale by the delivery of shabu. The defense of frame-up and denial was rejected for being inherently weak and unsupported by clear and convincing evidence. The Court emphasized that the testimonies of police officers enjoy the presumption of regularity in the performance of official duties, which the appellants failed to rebut.
Furthermore, the Court found the chain of custody of the seized drugs was preserved. The items were immediately marked at the scene by the apprehending officers, submitted for laboratory examination, and positively identified in court. The integrity and evidentiary value of the corpus delicti were thus intact. The appellants’ claim of an illegal warrantless arrest and search was unavailing, as the arrest was a valid consequence of a lawful buy-bust operation. Their guilt was proven beyond reasonable doubt.