GR 213607; (January, 2016) (Digest)
G.R. No. 213607, January 25, 2016
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. GLEN PIAD y BORI, RENATO VILLAROSA y PLATINO and NILO DAVIS y ARTIGA, Accused-Appellants.
FACTS
On April 23, 2005, based on information from a confidential informant, a police team conducted a buy-bust operation against a certain “Gamay,” later identified as accused-appellant Glen Piad, in Pasig City. PO1 Larry Arevalo acted as the poseur-buyer. At Piad’s house, PO1 Arevalo handed marked money to Piad in exchange for a plastic sachet of white crystalline substance. After the transaction, Piad was arrested. Upon arrest, Piad produced a metal box from his pocket containing two more plastic sachets. Inside the house, the backup team found accused-appellants Renato Villarosa, Nilo Davis, and Agustin Carbo (who later withdrew his appeal) sitting on the floor, surrounded by three sachets of white crystalline substance, aluminum foil, a tooter, and disposable lighters. All confiscated items were marked at the place of arrest. Laboratory examination confirmed the substances were methamphetamine hydrochloride.
The defense claimed the accused were having a birthday party when armed men in civilian clothes entered, searched the house, handcuffed them, and brought them to the police station, where monetary demands were made for their release.
The Regional Trial Court (RTC) found Piad guilty of illegal sale and illegal possession of dangerous drugs. It found Villarosa, Carbo, and Davis guilty of illegal possession of dangerous drugs during a party and illegal possession of drug paraphernalia during a party. The Court of Appeals affirmed the RTC decision. Hence, this appeal.
ISSUE
The core issue is whether the Court of Appeals correctly affirmed the convictions of the accused-appellants for violations of Republic Act No. 9165 (The Comprehensive Dangerous Drugs Act of 2002).
RULING
The Supreme Court DENIED the appeal and AFFIRMED the Court of Appeals Decision with MODIFICATIONS.
1. Regarding Glen Piad (Violation of Sections 5 and 11, Article II of R.A. No. 9165): The Court found all elements of illegal sale and illegal possession of dangerous drugs were proven. The buy-bust operation was legitimate, and the integrity and evidentiary value of the seized drugs were preserved through immediate marking at the scene. Piad’s defenses of denial and frame-up were rejected for being self-serving and unsupported by evidence.
2. Regarding Renato Villarosa and Nilo Davis (Violation of Sections 13 and 14, Article II of R.A. No. 9165): The Court found them guilty of illegal possession of dangerous drugs and drug paraphernalia during a party. The prosecution proved they were in proximate company with at least two persons (each other and Piad) and were in possession of the illicit items without legal authority. Their defenses were likewise rejected.
3. Modifications to the Penalties:
* For Glen Piad in Criminal Case No. 14087-D (illegal possession), the indeterminate penalty was modified to twelve (12) years and one (1) day, as minimum, to fourteen (14) years, as maximum.
* For Renato Villarosa and Nilo Davis in Criminal Case No. 14088-D (illegal possession during a party), the indeterminate penalty was modified to twelve (12) years and one (1) day, as minimum, to fourteen (14) years, as maximum.
The fines imposed by the RTC were affirmed.
The Court ordered the confiscated drugs and paraphernalia turned over to the Philippine Drug Enforcement Agency for destruction.
The Court held that the prosecution successfully established the guilt of the accused-appellants beyond reasonable doubt. The chain of custody over the seized items was not broken, and the procedural requirements under Section 21 of R.A. No. 9165 were substantially complied with, considering the marking was done immediately at the place of arrest.
