GR 192231; (February, 2013) (Digest)
G.R. No. 192231 ; February 13, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JAMES GALIDO Y NOBLE, Accused-Appellant.
FACTS
The prosecution presented a buy-bust operation conducted by Makati authorities on November 5, 2003. MADAC Operative Roberto Punzalan acted as the poseur-buyer and was introduced to accused-appellant James Galido. Punzalan handed two ₱100 bills to Galido, who in turn gave a plastic sachet of suspected shabu. Upon Punzalan’s signal, the team arrested Galido. A search incident to arrest yielded another plastic sachet from Galido’s pocket and the buy-bust money. The seized items were marked at the scene.
The defense interposed denial and frame-up. Galido claimed he was merely dressing up when armed men forcibly entered his house, accused him of selling drugs, and harassed him. He asserted that no drugs were recovered during the initial frisk at his home or at the barangay hall, and alleged he was later shown a sachet and slapped by an official. He was charged with illegal sale and possession of dangerous drugs under Republic Act No. 9165 .
ISSUE
Whether the prosecution proved the guilt of the accused beyond reasonable doubt for illegal sale and possession of dangerous drugs.
RULING
Yes, the Supreme Court affirmed the conviction. For illegal sale, all elements were established: the identities of the buyer and seller, the object (shabu), the consideration (₱200), and the delivery and payment. Punzalan’s straightforward testimony detailed the transaction and his positive identification of Galido and the marked corpus delicti. For illegal possession, the prosecution proved Galido was in possession of an unauthorized drug, recovered as an incident to a lawful arrest. His mere denial could not overcome the positive testimonies of the police officers, who are presumed to have performed their duties regularly in the absence of clear evidence of ill motive. The Court found no reason to disturb the trial court’s assessment of witness credibility. The chain of custody was also upheld, with the forensic chemist confirming the substances were methamphetamine hydrochloride. The penalties imposed by the lower courts were sustained.