GR 188976; (June, 2010) (Digest)
G.R. No. 188976 ; June 29, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JAKAR MAPAN LE y SUBA and RODEL DEL CASTILLO y SACRUZ, Accused-Appellants.
FACTS
The prosecution’s evidence established that a buy-bust operation was conducted against appellants Jakar Mapan Le and Rodel Del Castillo based on a tip from a confidential informant. PO2 Richard Noble acted as the poseur-buyer. At the target location, the informant introduced PO2 Noble to Le (“Ankar”). After Noble handed marked money to Le, Le instructed Del Castillo (“Rodel”) to give Noble a plastic sachet. Upon receiving the sachet, Noble gave a pre-arranged signal, leading to the arrest of both appellants. The seized item was marked and later confirmed by forensic examination to contain methamphetamine hydrochloride.
Appellants presented a different version, claiming they were victims of a frame-up. Le testified that police officers forcibly entered his home without a warrant, frisked him, and found nothing, yet arrested him. He alleged that PO2 Noble later demanded money for his release. Del Castillo claimed he was merely washing his hands near Le’s house when police apprehended him. Both denied any involvement in a drug transaction.
ISSUE
Whether the guilt of the accused-appellants for the illegal sale of dangerous drugs was proven beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction, upholding the findings of the trial court and the Court of Appeals. The core of the offense under Section 5 of R.A. 9165 is the consummated sale of illicit drugs. The prosecution successfully proved all its elements: the identities of the buyer and seller, the object and consideration, and the delivery of the drugs and payment. The testimonies of the police officers, who were presumed to have performed their duties regularly in the absence of proof to the contrary, were consistent and credible in detailing the transaction.
The Court rejected the defense of frame-up and denial for being inherently weak. Appellants failed to present clear and convincing evidence of any improper motive on the part of the arresting officers, such as the alleged extortion. Their failure to file any administrative or criminal complaint against the officers further weakened their claim. The Court also found that the integrity and evidentiary value of the seized drug were preserved, as the chain of custody was sufficiently established through testimony on the marking and handling of the evidence. The penalty of life imprisonment and a fine of One Million Pesos (PhP 1,000,000) for each appellant, as mandated by law, was affirmed.