G.R. No. 190180 ; November 27, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. MARISSA CASTILLO y ALIGNAY, Accused-Appellant.

FACTS

Accused-appellant Marissa Castillo was charged with violation of Sections 5 and 11, Article II of R.A. No. 9165 for sale and possession of dangerous drugs. The prosecution evidence established that a buy-bust operation was conducted against Castillo based on a tip from a confidential informant. PO2 Thaddeus Santos acted as the poseur-buyer and was given marked money. At the target area, the informant introduced Santos to Castillo. Upon being asked if she had shabu, Castillo produced three plastic sachets, gave one to Santos in exchange for the marked money, and was subsequently arrested. The two other sachets were recovered from her. The seized items tested positive for methylamphetamine hydrochloride.
The defense presented a different version. Castillo and her daughter testified that on the date in question, they were at home when police officers forcibly entered without a warrant. The officers allegedly searched the house, found nothing, but still arrested Castillo. She claimed the charges were fabricated and denied selling any drugs.

ISSUE

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

RULING

The Supreme Court affirmed the conviction. The Court upheld the findings of the trial court and the Court of Appeals, giving great weight to the credibility of the police officers’ testimonies which detailed a clear and consistent narrative of a legitimate buy-bust operation. The Court found the elements of both illegal sale and possession were sufficiently established: the identity of the buyer and seller, the object and consideration, the delivery, and Castillo’s possession of the two other sachets without legal authority.
The Court rejected the defense of denial and frame-up, ruling it to be inherently weak. It emphasized that such defenses cannot prevail over the positive identification by the police officers, absent clear and convincing evidence of ill motive on their part. The corroborating testimony of Castillo’s daughter was deemed insufficient, as it came from an interested witness. The Court also found that the chain of custody of the seized drugs was properly preserved, as the items were immediately marked at the scene and subsequently subjected to laboratory examination, which confirmed their illicit nature. The integrity and evidentiary value of the corpus delicti were thus maintained.