Title
People vs. Allen Udtojan Mantalaba
Case
G.R. No. 186227
Decision Date
Jul 20, 2011
The court upheld the conviction of Allen Mantalaba for violating drug laws, affirming the lower court's decision on guilt and modifying the penalty due to his minority status at the time of the crime.

Case Digest (G.R. No. 207606)
Expanded Legal Reasoning Model

Facts:

  • Background and Parties
    • The appellant, Allen Udtojan Mantalaba, was seventeen (17) years old at the time of the alleged offenses.
    • The prosecution is the People of the Philippines.
    • The case concerns violations of Sections 5 and 11, Article II of Republic Act No. 9165 (The Comprehensive Dangerous Drugs Act).
  • Buy-Bust Operation
    • The Task Force RACER in Butuan City received information that appellant was selling shabu in Barangay 3, Agao District.
    • A buy-bust team was organized, composed of PO1 Randy Pajo, PO1 Eric Simon, and two poseur-buyers, with two marked P100 bills.
    • On October 1, 2003, at around 7 PM, the buy-bust operation was conducted in the specified area.
    • Appellant was approached by the poseur-buyers while sitting alone.
    • After the transaction, the appellant handed a sachet of shabu in exchange for the marked money.
    • Police officers arrested appellant immediately after the sale and found:
      • One big sachet of shabu on his person.
      • Two pieces of marked money thrown on the ground.
      • One small sachet of shabu also recovered.
    • The search and inventory of the seized items were conducted in the presence of barangay officials Richard S. Tandoy and Gresilda B. Tumala.
  • Laboratory Examination
    • The seized substances and appellant's person were subjected to laboratory examination.
    • Police Inspector Virginia Sison-Gucor, forensic chemical officer, conducted the tests.
    • Results confirmed that the plastic sachets contained methamphetamine hydrochloride.
    • Appellant tested positive for the presence of bright orange ultraviolet fluorescent powder.
  • Charges
    • Two Informations were filed:
      • Criminal Case No. 10250 for selling 0.0412 grams of shabu.
      • Criminal Case No. 10251 for possession of 0.6131 grams of shabu.
    • The cases were consolidated and jointly tried.
    • Appellant pleaded not guilty.
  • Trial Court and Court of Appeals Decisions
    • The Regional Trial Court (RTC) found appellant guilty beyond reasonable doubt.
    • Penalty imposed:
      • Reclusion perpetua and fine of P500,000 for sale (Criminal Case No. 10250).
      • Prision mayor for 6 years and one day to 8 years, and fine of P300,000 for possession (Criminal Case No. 10251).
    • The Court of Appeals affirmed the RTC decisions in toto.
  • Appellant’s Arguments on Appeal
    • Prosecution failed to prove actual sale.
    • Chain of custody of the seized shabu was not established.
    • Presumption of innocence and burden of proof were not observed.

Issues:

  • Whether the prosecution proved beyond reasonable doubt the actual sale of shabu to appellant.
  • Whether the chain of custody of the seized evidence was properly established.
  • Whether the accused's right to presumption of innocence and proper burden of proof was respected.
  • Whether the appellant, as a minor at time of the offense, is entitled to suspension of sentence under the law.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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