G.R. No. 140919; March 20, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BUTCH BUCAO LEE, accused-appellant.

FACTS

Accused-appellant Butch Bucao Lee was charged with violating Section 15 of Republic Act No. 6425 (The Dangerous Drugs Act of 1972), as amended, for the unlawful sale of 490.60 grams of methylamphetamine hydrochloride (shabu). The prosecution evidence established that on February 20, 1999, a buy-bust operation was conducted by police officers from the CIDG. PO2 Tyrone Torrano acted as the poseur-buyer and met Lee in front of a convenience store in Quezon City. After being introduced by a confidential informant and shown the buy-bust money, Lee left and later returned via taxi, delivering a National Bookstore plastic bag containing ten sachets of a white crystalline substance. Upon inspection and confirmation, Torrano gave the pre-arranged signal, leading to Lee’s arrest.
The defense presented a starkly different version. Lee testified that on the night in question, he was merely waiting for a ride when he was suddenly accosted by armed men who forced him into a vehicle, brought him to Camp Crame, and demanded money. He claimed the arrest was a frame-up and that he was illegally detained and tortured to admit ownership of the seized drugs. He argued that the prosecution failed to prove his guilt beyond reasonable doubt and that the evidence was planted.

ISSUE

The core issue is whether the prosecution successfully proved the guilt of the accused-appellant for the illegal sale of dangerous drugs beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court found the testimonies of the police officers involved in the buy-bust operation to be credible, straightforward, and consistent. The detailed account of the transaction—from the initial contact, the negotiation, the presentation of the marked money, the delivery of the plastic bag containing the shabu, to the subsequent arrest—was deemed sufficient to establish all the elements of the crime of illegal sale of a regulated drug. The defense of frame-up and denial was rejected for being inherently weak and unsupported by clear and convincing evidence. The Court emphasized that such defenses cannot prevail over the positive identification by the police officers, who are presumed to have performed their duties regularly in the absence of proof to the contrary.
Furthermore, the chain of custody of the seized drugs was adequately established. The forensic chemist confirmed that the substance recovered from Lee tested positive for methylamphetamine hydrochloride. The weight of 490.60 grams fell under the threshold for the imposition of reclusion perpetua and a fine. The penalty imposed by the trial court was thus affirmed, and the confiscated shabu was ordered forfeited in favor of the government. The appeal was dismissed for lack of merit.