G.R. No. 139114 ; October 23, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROMAN LACAP Y CAILLES, accused-appellant.

FACTS

The National Bureau of Investigation (NBI) received information about shabu trafficking by Eduardo Contreras and Alice Esmenia. After verification, a buy-bust operation was planned. An NBI agent, posing as a buyer named Ricky Baconawa, negotiated for the purchase of two kilos of shabu. After several failed attempts, the transaction was set for April 7, 1997, at a house on Scout Rallos St., Quezon City. The agent, along with Contreras and Esmenia, met accused-appellant Roman Lacap inside the house. After an hour of negotiation, Lacap showed the agent two plastic bags containing a white crystalline substance, later confirmed as 1,798.90 grams of shabu. Upon seeing the drugs, the agent gave a pre-arranged signal, and the NBI team arrested Lacap as he was opening a case containing the boodle money.
Accused-appellant denied the charges, claiming he was merely at the house to inquire about a vehicle for sale from Contreras. He alleged he was framed, and the NBI operatives planted the evidence. The trial court found him guilty of violating the Dangerous Drugs Act ( Republic Act No. 6425 ) for the sale of methamphetamine hydrochloride and sentenced him to reclusion perpetua and a fine. He appealed, arguing the prosecution failed to prove his guilt beyond reasonable doubt and that the evidence was inadmissible.

ISSUE

Whether the guilt of the accused-appellant for the illegal sale of dangerous drugs was proven beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction. For a successful prosecution of illegal sale of dangerous drugs, the following elements must be established: (1) the identity of the buyer and seller, object, and consideration; and (2) the delivery of the thing sold and the payment. All these elements were convincingly proven. The testimony of the poseur-buyer, a law enforcer, deserves full faith and credit in the absence of evidence of ill motive. His detailed account of the negotiation, the presentation of the shabu by Lacap, and the subsequent arrest was clear and consistent. The defense of frame-up was rejected, as it is a common defense easily fabricated and which must be supported by strong and convincing evidence, which Lacap failed to provide. The Court found no reason to deviate from the trial court’s assessment of the credibility of the prosecution witnesses. The chain of custody of the seized drugs was also properly established, from their confiscation to their presentation in court. The arrest was a legitimate result of a valid buy-bust operation, and the seized shabu was admissible as evidence. The penalty of reclusion perpetua and the fine were affirmed as being in accordance with law.