GR 97930; (May, 1992) (Digest)
G.R. No. 97930 May 27, 1992
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. STANLEY BLAS, accused-appellant.
FACTS
Accused-appellant Stanley Blas was charged with the illegal sale of shabu (methamphetamine hydrochloride). The prosecution evidence established that on July 19, 1989, based on information from an informant, the Sixth Regional Narcotic Command in Iloilo City conducted a surveillance and test-buy operation. CIC Freddie Cartel acted as a poseur-buyer and bought a deck of shabu worth P200.00 from Blas at Room H-4 of Bayani de Luxe Hotel. Later that same evening, a buy-bust operation was conducted. Cartel returned to the room, bought another deck of shabu with marked money, and gave a pre-arranged signal. The NARCOM team then arrested Blas and seized the marked money, shabu, and drug paraphernalia from the room. Blas denied the charges, claiming he was framed-up, that the evidence was planted, and that the items were seized without a search warrant during a warrantless arrest where several men barged into his hotel room.
ISSUE
The main issues, as framed by the assigned errors, are: (1) the propriety of the trial court’s consideration of the test-buy and buy-bust operations; (2) the correctness of the trial court’s conclusion that Blas was in possession and owned the shabu and not that they were planted; and (3) the admissibility of the exhibits allegedly obtained illegally without a search warrant.
RULING
The Supreme Court affirmed the conviction but modified the penalty. The Court ruled that the trial court correctly considered the operations. The testimonies of the prosecution witnesses, who were law enforcers presumed to have regularly performed their duty, were credible and consistent. The defense of frame-up was not proven by clear and convincing evidence and was deemed a weak defense. The warrantless arrest and seizure were valid as they were incidental to a lawful arrest made after a consummated sale during a buy-bust operation. The Court upheld the findings of the trial court on witness credibility. However, the penalty was modified from reclusion perpetua to life imprisonment, as the prescribed penalty under the Dangerous Drugs Act is life imprisonment to death, and reclusion perpetua is not interchangeable with life imprisonment. The decision was AFFIRMED with MODIFICATION.