GR 214440; (June, 2016) (Digest)
G.R. No. 214440 . June 15, 2016
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ALEX MENDEZ RAFOLS, ACCUSED-APPELLANT.
FACTS
The accused-appellant, Alex Mendez Rafols, was charged with violations of Sections 5 (Illegal Sale) and 11 (Illegal Possession) of Article II of Republic Act No. 9165 . The prosecution alleged that on December 5, 2007, a buy-bust operation was conducted by PDEA agents in Cebu City. A poseur-buyer successfully purchased one plastic sachet of shabu from Rafols. Upon his arrest, a subsequent body search yielded six more plastic sachets of shabu and the marked buy-bust money. The seized items were marked, inventoried, and photographed at the PDEA office in the presence of the accused, barangay tanods, and a media representative, before being submitted to the crime laboratory, where they tested positive for methamphetamine hydrochloride.
Rafols denied the charges, claiming he was framed. He testified that he was on his way to buy medicine when apprehended by men in civilian clothes, who later brought him to the police station. He alleged the evidence was planted, citing a prior arrest for drugs, but admitted he did not file any case against the arresting officers. The Regional Trial Court convicted Rafols, a decision affirmed by the Court of Appeals.
ISSUE
Whether the Court of Appeals erred in affirming Rafols’s conviction for illegal sale and possession of dangerous drugs.
RULING
The Supreme Court affirmed the conviction. The prosecution successfully established all elements of the crimes. For illegal sale, it proved the transaction occurred and presented the corpus delicti. For illegal possession, it proved Rafols possessed the drugs without legal authority. The Court upheld the validity of the warrantless arrest and the subsequent search as incidental to a lawful arrest. The integrity and evidentiary value of the seized drugs were preserved through an unbroken chain of custody. The prescribed procedure under Section 21 of RA 9165 was substantially complied with, as the inventory and photography were conducted in the presence of the accused and required witnesses. The defense of denial and frame-up, being inherently weak, could not prevail over the positive testimonies of the police officers, who were presumed to have performed their duties regularly in the absence of clear evidence of ill motive. The minor inconsistencies in the testimonies did not affect the core facts of the sale and seizure.