G.R. No. 184599; November 24, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. TEDDY BATOON y MIGUEL and MELCHOR BATOON y MIGUEL, Accused-Appellants.

FACTS

Accused-appellants Teddy and Melchor Batoon were charged with illegal sale and possession of dangerous drugs. The prosecution evidence established that a buy-bust operation was conducted based on reports of their drug peddling. PO2 Excel Vicente acted as poseur-buyer and handed a marked PhP 500 bill to Melchor. Melchor then approached Teddy, gave him the money, and received a plastic sachet in return, which he handed to PO2 Vicente. Upon the pre-arranged signal, the team arrested both brothers. A search incident to arrest yielded the marked money from Teddy and three additional plastic sachets from his possession. Forensic examination confirmed all sachets contained methamphetamine hydrochloride.
In their defense, the brothers denied the charges and claimed they were framed. They testified that Melchor was arbitrarily accosted and assaulted by unidentified men, and when Teddy approached to inquire, he too was assaulted. They alleged they were forced into a vehicle, their money and belongings were taken, and they were subsequently maltreated while in custody. They presented witnesses to corroborate their arrest and the alleged physical abuse.

ISSUE

Whether the Court of Appeals correctly affirmed the conviction of accused-appellants for violations of Sections 5 and 11 of Republic Act No. 9165.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court found the prosecution successfully proved all elements of the crimes beyond reasonable doubt. For illegal sale, the evidence clearly showed a completed transaction where Melchor received the marked money and delivered the shabu to the poseur-buyer, with Teddy as the source. The defense of denial and frame-up was inherently weak and could not prevail over the positive and credible testimonies of the police officers, who were presumed to have performed their duties regularly in the absence of evidence of ill motive.
Regarding illegal possession, although the three additional sachets were found solely on Teddy, the Court ruled that conspiracy was established. The coordinated actions between the brothers—where Melchor collected payment and retrieved the drugs from Teddy—demonstrated a common design to engage in the illegal drug trade. Under conspiracy, the act of one is the act of all. Therefore, both were liable for possession of the drugs found on Teddy, as they had constructive joint possession and knowledge of the illicit items. The chain of custody of the seized drugs was also properly established, preserving their integrity as evidence.