G.R. No. 107623 February 23, 1994
People of the Philippines, plaintiff-appellee, vs. Angelita Manalo y Dela Paz, accused-appellant.

FACTS

Accused-appellant Angelita Manalo was previously arrested for drug violations in June 1990. In August 1991, the Dangerous Drugs Enforcement Division (DDED) of the Pasig Police Station received confidential information about her ongoing drug trafficking activities at Rotonda, Caniogan, Pasig. A surveillance confirmed this, leading to the formation of a buy-bust team on January 24, 1992. PO2 Adonis Corpuz acted as the poseur-buyer. At around 10:00 PM, Corpuz approached Manalo, said “Paiskor ng piso” (meaning to buy P100 worth), handed her a marked P100 bill, and in exchange, Manalo gave him a deck of “shabu.” Upon the consummated sale, Corpuz signaled his back-up team to arrest her. A subsequent body search at the police station by PO2 June Valencia recovered the marked money, a deck of shabu, a heat-sealed plastic bag with marijuana leaves from her rectum, and a plastic bag containing shabu inserted in her vagina. Chemical examinations confirmed the substances were methamphetamine hydrochloride (shabu) and marijuana. Manalo’s urine sample also tested positive for methamphetamine. She was charged in two separate Informations: one for possession of marijuana (Criminal Case No. 1869-D-92) and another for sale of shabu and possession of shabu and paraphernalia (Criminal Case No. 1870-D-92). At trial, Manalo denied the sale, claiming she was forcibly taken from a jeep by police officers and that no drugs were found on her during initial searches. The trial court acquitted her in the marijuana possession case due to the prosecution’s failure to present PO2 Valencia, but convicted her for the sale of shabu, sentencing her to life imprisonment and a P30,000 fine.

ISSUE

1. Whether the trial court erred in giving credence to the prosecution’s version of a legitimate buy-bust operation and in finding the accused guilty beyond reasonable doubt for the sale of methamphetamine hydrochloride.

RULING

The Supreme Court affirmed the conviction. The Court held that: (1) It is not improbable for drug pushers to sell to strangers or to have ready stocks for immediate sale, dismissing the claim that the transaction was incredible. (2) The operation constituted a valid entrapment, not instigation, as the intent to commit the crime originated from the accused, and buy-bust operations are a recognized means of apprehending drug offenders in flagrante delicto. (3) The alleged irregularities (e.g., lack of blotter annotations or arrest reports) did not overcome the presumption of regularity in the performance of official duties by the police officers, especially given the clear evidence of the sale. (4) The prosecution proved the corpus delicti through the testimony of PO2 Corpuz and the chemical analysis reports, and the defense failed to present any license or authority to sell the regulated drug. (5) The accused-appellant’s defense relied solely on her uncorroborated testimony, and she failed to present supporting witnesses or file charges against the alleged police maltreatment. Therefore, the evidence established her guilt beyond reasonable doubt for violating Section 15, Article III of Republic Act No. 6425 .