GR 187496; (February, 2013) (Digest)
G.R. No. 187496; February 06, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. MALIK MANALAO y ALAUYA, Accused-Appellant.
FACTS
Accused-appellant Malik Manalao was charged with illegal sale and illegal possession of dangerous drugs under Sections 5 and 11, Article II of Republic Act No. 9165. The prosecution evidence established that based on reports of his drug activities, a buy-bust operation was conducted on June 15, 2004, in Tubod, Lanao del Norte. A civilian agent acted as poseur-buyer and handed marked money to Manalao, who in turn gave one deck of shabu. Upon arrest, a search yielded three more decks of shabu and the marked money from his person. The seized items were marked at the police station.
Manalao denied the charges, claiming he was arrested on a different date, June 9, 2004. He testified he was at a restaurant when a friend asked him to hand a wrapped item to another person. Shortly after, police officers arrived, arrested him, and took money from him. He asserted the drugs were planted and denied any involvement in a sale.
ISSUE
Whether the Court of Appeals erred in affirming Manalao’s conviction for illegal sale and illegal possession of dangerous drugs.
RULING
The Supreme Court affirmed the conviction. The prosecution successfully established all elements of the crimes. For illegal sale, the evidence proved the identity of the buyer and seller, the object and consideration, and the delivery of the shabu. For illegal possession, the prosecution proved Manalao was in possession of the three additional decks without legal authority. The arrest was lawful, being effected after a valid buy-bust operation, and the subsequent warrantless search incidental to arrest was likewise valid, yielding the other drugs.
The Court found the defense of denial and frame-up unavailing. Manalao’s testimony was deemed self-serving and uncorroborated, failing to overcome the positive and credible testimonies of the police officers. The Court upheld the findings of the trial court on witness credibility, noting no ill motive was shown for the officers to falsely testify. The integrity and evidentiary value of the seized drugs were preserved, as the chain of custody was shown through testimony and the forensic chemist’s report. The minor inconsistency regarding the date of arrest (June 15 per prosecution vs. June 9 per defense) was deemed inconsequential and did not cast doubt on the occurrence of the buy-bust. Thus, guilt was proven beyond reasonable doubt.