G.R. No. 191193; November 14, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. GODOFREDO MARIANO y FELICIANO and ALLAN DORINGO y GUNAN, Accused-Appellants.

FACTS

Acting on a tip, a buy-bust team was formed with PO1 David Olleres, Jr. as the poseur-buyer. On October 17, 2004, the team proceeded to a house in Bulan, Sorsogon. PO1 Olleres and PO3 Virgilio Razo entered and witnessed an ongoing pot session. They asked for “Galog” and were introduced to accused-appellant Godofredo Mariano. Godofredo left and returned with two plastic sachets of shabu, which he sold to PO1 Olleres for a marked P1,000 bill. Accused-appellant Allan Doringo then offered PO3 Razo two more sachets, which were purchased using marked P600 bills. After the transactions, the police requested an actual test, during which Godofredo provided drug paraphernalia. Appellants were then arrested. The seized items were marked at the scene and later confirmed by forensic examination to be methamphetamine hydrochloride.
The defense presented a different narrative. Allan claimed he merely entered the house, saw shabu on the table, and was then threatened with a knife by a certain Ludy before being forced to go with the police. Godofredo admitted being a drug user and stated he was at the location to buy shabu, witnessing the arrest of Allan before he himself was apprehended. Both denied being drug sellers and claimed they were forced to sign documents without reading them.

ISSUE

Whether the guilt of accused-appellants Godofredo Mariano and Allan Doringo for violations of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the convictions. 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 buy-bust operation. The prosecution successfully established all elements of illegal sale of dangerous drugs: the identity of the buyer and seller, the object and consideration, and the delivery. For Godofredo, the prosecution also proved illegal possession of drug paraphernalia. The defense of frame-up and denial was rejected for being inherently weak and unsupported by clear and convincing evidence. The Court found no ill motive on the part of the police officers to falsely testify against the appellants.
Furthermore, the Court ruled that the integrity and evidentiary value of the seized drugs were preserved. The buy-bust team complied with the chain of custody rule by immediately marking the seized items at the place of arrest, with these same items being presented in court and identified by the arresting officers. The defense failed to substantiate any allegation of irregularity in the handling of the evidence. The minor inconsistencies in the testimonies pertained to trivial details and did not affect the core facts of the sale. Consequently, the convictions for illegal sale under Section 5 and, for Godofredo, illegal possession of paraphernalia under Section 12 of R.A. 9165 were sustained.