G.R. No. 177324; March 30, 2011.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. REYNALD DELA CRUZ Y LIBANTOCIA, Accused-Appellant.

FACTS

Accused-appellant Reynald Dela Cruz y Libantocia was charged with violation of Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) for selling 0.20 gram of methamphetamine hydrochloride (shabu). The prosecution’s version, based on the testimonies of PO3 Bernard Amigo and PO2 Jaime Ocampo, is that on March 30, 2003, a police team conducted a buy-bust operation on Yale Street, Cubao, Quezon City, after an informant reported drug selling activity. PO2 Ocampo acted as poseur-buyer, using two marked ₱100 bills to purchase shabu from Dela Cruz. Upon receiving the plastic sachet, Ocampo gave a pre-arranged signal, leading to Dela Cruz’s arrest and the recovery of the buy-bust money. The seized item was marked and later confirmed by the PNP Crime Laboratory to be shabu.
The defense, presented through Dela Cruz, his aunt Adoracion Salcedo, and his kumare Nora Cruz, claimed frame-up. Dela Cruz denied selling drugs and asserted that he was arrested while fixing a trash can in an eskinita between Yale and Oxford Streets. He claimed he was in the area to deliver a banig to Nora and to have his money changed at a store. The defense witnesses supported his presence in the area for non-drug-related purposes but gave accounts that the trial court found inconsistent with Dela Cruz’s own testimony.

ISSUE

Whether the Court of Appeals erred in affirming the Regional Trial Court’s decision finding accused-appellant Reynald Dela Cruz y Libantocia guilty beyond reasonable doubt of illegal sale of dangerous drugs under Section 5, Article II of R.A. No. 9165.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the Decision of the Court of Appeals. The Court upheld the conviction of accused-appellant Reynald Dela Cruz for illegal sale of shabu.
The Court ruled that all elements of illegal sale of dangerous drugs were proven: (1) the identity of the buyer and seller, the object, and the consideration; and (2) the delivery of the thing sold and the payment. The testimonies of the police officers, particularly PO2 Ocampo as the poseur-buyer, were found credible and sufficient to establish these elements. The marked money was recovered from Dela Cruz, and the plastic sachet he sold was positively identified and confirmed to contain shabu.
The Court rejected the defense of frame-up, noting it was uncorroborated and inherently weak. It found the testimonies of the defense witnesses inconsistent with each other and with Dela Cruz’s own account regarding his purpose for being at the crime scene. The Court also upheld the presumption of regularity in the performance of official duties by the police officers, as there was no evidence of any ill motive on their part to falsely accuse Dela Cruz. The minor inconsistencies in the police officers’ testimonies were deemed inconsequential and did not affect the core finding of the sale. The chain of custody of the seized drug was also sufficiently established. Therefore, the guilt of the accused was proven beyond reasonable doubt. The penalty of life imprisonment and a fine of ₱500,000.00 was affirmed.