Facts:

The case involves Radito Aurelio y Reyes, also known as "Jack," as the petitioner against the People of the Philippines as the respondent. The events leading to the case began on October 17, 2002, in Mandaluyong City, where the petitioner was accused of violating Sections 5 and 11, Article II of Republic Act No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002. Two Informations were filed against him, with Criminal Case No. MC-02-6019-D alleging the illegal sale of shabu and Criminal Case No. MC-02-6020-D alleging illegal possession of shabu.

The prosecution's case was based on the testimony of Police Chief Inspector Bien B. Calag, Jr., who directed a buy-bust operation after receiving reports of rampant shabu sales in the area. SPO2 Julius Bacero was designated as the poseur-buyer. During the operation, Bacero successfully purchased a sachet of shabu from the petitioner for P100.00, after which he was arrested, and another sachet of shabu wa...

Facts:

Filing of Criminal Informations and Charges

• On October 22, 2002, two separate Informations were filed with the RTC of Mandaluyong City against petitioner Radito Aurelio y Reyes (alias Jack) for alleged violations of Sections 5 and 11, Article II of Republic Act No. 9165.
• The charges pertained respectively to:
• The illegal sale, delivery, distribution, transport, or sale of a small sachet containing 0.05 gram of shabu for P100.00 (Criminal Case No. MC-02-6019-D).
• The illegal possession of a small sachet containing 0.12 gram of shabu without the necessary license or prescription (Criminal Case No. MC-02-6020-D).
• The cases were subsequently consolidated upon motion of the prosecution, and at arraignment, the petitioner pleaded “not guilty” to both charges.

The Buy-Bust Operation and Investigative Elements

• On October 17, 2002, the police received a report regarding rampant shabu selling in Mandaluyong City through an informant.
• Acting on the report, Police Chief Inspector Bien B. Calag, Jr. instructed SPO2 Julius Bacero and PO1 Ronald Jacuba, along with other personnel from Task Force Magpalakas and the Mayor’s Action Command, to verify the information and conduct surveillance.
• At around 4:30 p.m., the buy-bust team proceeded to the petitioner’s residence at 522 M. Vasquez Street, Barangay Harapin ang Bukas.
• Upon arrival, SPO2 Bacero knocked on the door; the petitioner briefly interacted by inviting the officer to wait before eventually handing over a small plastic sachet containing a white crystalline substance, in exchange for a marked P100 bill.

Prosecution’s Version of Events

• The prosecution’s account details a prearranged entrapment operation:
• SPO2 Bacero, acting as the poseur-buyer, confirmed the information provided by an informant and participated directly in the transaction.
• Following a staged buy-bust operation, the petitioner was arrested by SPO2 Bacero and PO1 Jacuba after the exchange, and was subsequently read his rights.
• Evidence comprised the marked P100 used in the transaction, two plastic sachets (one directly from the transaction and the other recovered during an incidental search), and the forensic report confirming the presence of methamphetamine hydrochloride (shabu).
• The testimonies of SPO2 Bacero and PO1 Jacuba were consistent with the documentary and object evidence submitted.

Petitioner’s Version of Events and Defenses

• The petitioner denied the allegations, presenting an alternate narrative:
• He claimed that on the afternoon of October 17, 2002, he was at a neighbor’s house watching television and later went out to buy cigarettes.
• He stated that he was then abducted by two men who later took him to an alley, a barangay hall, City Hall, and eventually to the Task Force Magpalakas office.
• According to his account, he was extorted by SPO2 Bacero – who allegedly demanded P30,000.00 for his liberty – and that the shabu was planted by the police officers.
• His defenses, based on denial and frame-up, were supported by the testimonies of his long-time neighbor, Julieta Dulia, and his sister, Teresita Aurelio; however, their accounts varied in certain details.

Decisions of Lower Courts

• The Regional Trial Court rendered its judgment on March 2, 2005, convicting the petitioner for both charges:
• He was sentenced to twelve (12) years imprisonment for each offense, with forfeiture of the illegally acquired evidence in favor of the government.
• The Court of Appeals (CA) affirmed the RTC judgment with modifications by increasing the penalties:
• In Criminal Case No. MC-02-6019-D (sale), the penalty was modified to life imprisonment and a fine of P500,000.00.
• In Criminal Case No. MC-02-6020-D (possession), the penalty was fixed as an indeterminate sentence of twelve (12) years and one (1) day to twenty (20) years along with a fine of P300,000.00.
• The petitioner’s subsequent Motion for Reconsideration was denied.

Issues Raised by the Petitioner

• The petitioner contended that both the trial and appellate courts erred by giving undue credence to the testimonies of police witnesses, especially considering alleged inconsistencies in materially trivial matters.
• He argued that inconsistencies in the prosecution’s testimonies, including timing discrepancies and procedural nuances, should have led to his acquittal.
• The petitioner also charged that there was no actual buy-bust operation, asserting that the entire incident was a frame-up, and that extortion was involved by the officers, a claim unsupported by any formal complaint.

Issue:

• Whether the minor inconsistencies in the testimonies of the prosecution witnesses concerning insignificant details are sufficient grounds to reverse the conviction.
• Whether the defense of denial and the claim of frame-up, which allege that no bona fide buy-bust operation was conducted and that the shabu was planted, can prevail in light of the established credible evidence.
• Whether the trial and appellate courts erred in giving more weight to the prosecution’s evidence over the petitioner’s conflicting testimonies by his supporting witnesses.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)