G.R. No. 187741 ; August 8, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. PETER M. CAMPOMANES and EDITH MENDOZA, Accused-Appellants.

FACTS

On March 22, 2003, a buy-bust team was dispatched to Francisco St., Bagong Ilog, Pasig City, following reports of drug activities by alias “Pete.” PO1 Allan Mapula acted as poseur-buyer. Upon arrival, petitioner Edith Mendoza opened the gate. The informant indicated PO1 Mapula wished to buy. Mapula handed Mendoza a marked ₱100 bill, stating he wanted “Piso lang.” Mendoza took the money, went inside, and later, Peter Campomanes emerged and handed Mapula a plastic sachet containing white crystalline substance. Mapula then signaled the bust. Campomanes was apprehended after a brief chase, and the marked money was recovered from him. Drug paraphernalia were also seen on a table near Mendoza. The seized items were marked and later confirmed by forensic examination to be methylamphetamine hydrochloride.
Accused Campomanes and Mendoza denied the charges, claiming the police officers illegally entered the house, conducted a warrantless search, and arrested them without cause. They alleged the evidence was planted. The Regional Trial Court convicted both of illegal sale of dangerous drugs under Section 5, Article II of R.A. No. 9165 . The Court of Appeals affirmed the conviction. Campomanes died pending appeal, leaving Mendoza as the sole appellant before the Supreme Court.

ISSUE

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

RULING

Yes, the Supreme Court affirmed Mendoza’s conviction. The Court found the prosecution successfully established all elements of illegal sale: (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 detailed testimony of PO1 Mapula, the poseur-buyer, was credible and consistent. He clearly narrated how Mendoza acted as the conduit by receiving the marked money and facilitating the transaction, which was consummated when Campomanes delivered the shabu. Her active participation constituted conspiracy in the sale.
The defense of frame-up and illegal search was rejected for being unsubstantiated and inherently weak. No ill motive was proven on the part of the police officers to falsely accuse the appellant. The Court upheld the presumption of regularity in the performance of official duties by the buy-bust team. While the defense raised issues on the chain of custody, the Court ruled that the integrity and evidentiary value of the seized drug were preserved. The sachet was immediately marked at the scene in the presence of Mendoza, and its examination confirmed it was shabu. Minor procedural lapses did not negate the established fact of the sale. Thus, Mendoza’s guilt was proven beyond reasonable doubt.