G.R. No. 106874 January 21, 1994
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENATO DE LOS REYES Y SOLTEO, accused-appellant.

FACTS

Accused-appellant Renato de los Reyes was charged with violating Section 15, Article III of Republic Act No. 6425 (Dangerous Drugs Act), as amended, for the illegal sale of methamphetamine hydrochloride (shabu). The information alleged that on July 6, 1991, in Quezon City, he willfully and unlawfully sold and delivered 0.02 grams of shabu worth P200.00 to Pat. Rodolfo Mercado, who acted as a poseur-buyer. After pleading not guilty, the trial court found him guilty beyond reasonable doubt and sentenced him to life imprisonment and a fine of P20,000.00.
The prosecution’s evidence established that the District Anti-Narcotics Division had placed accused-appellant under surveillance for suspected drug activities. A buy-bust team was formed, and on July 16, 1991, Pat. Rodolfo Mercado, acting as poseur-buyer, accompanied by an informant, went to accused-appellant’s house. The informant introduced Mercado, and accused-appellant agreed to sell shabu, handing over an aluminum foil packet containing 0.02 grams of shabu in exchange for two P100 bills. Mercado then signaled his team, who arrested accused-appellant and recovered the marked money and drug paraphernalia. Forensic tests confirmed the substance was shabu, and an ultraviolet examination revealed fluorescent powder on accused-appellant’s person from the marked money.
Accused-appellant appealed, arguing the trial court erred in finding him guilty. He challenged the regularity of the police procedures, including the lack of annotation of the surveillance and marked money in a police blotter, the absence of distinguishing marks on the seized shabu before laboratory submission, the failure to issue receipts for confiscated items, non-compliance with Dangerous Drugs Board regulations on inventory, and the non-presentation of the informant as a witness. He also claimed inducement and frame-up.

ISSUE

Whether the trial court erred in finding accused-appellant guilty beyond reasonable doubt of illegal sale of shabu despite the alleged irregularities in the police procedures and the defenses of inducement and frame-up.

RULING

The Supreme Court affirmed the trial court’s decision, finding accused-appellant guilty beyond reasonable doubt. The Court held that the alleged procedural irregularities did not undermine the prosecution’s case, as the commission of the crime was consummated upon the sale and delivery of the shabu to the poseur-buyer, which was positively and categorically established by prosecution witnesses. The failure to annotate details in a police blotter, mark the seized item immediately, issue receipts, or comply with DDB regulations were deemed collateral matters that did not affect the essence of the crime. The non-presentation of the informant was not fatal, as his testimony was not essential for conviction. The defense of inducement was rejected, as the operation constituted legitimate entrapment, and the claim of frame-up was unsupported by strong and convincing evidence to overcome the trial court’s findings on the credibility of the prosecution witnesses.