G.R. No. 191064 - People vs. Araneta y Abella

The accused, Rolando Araneta y Abella (“Botong”) and Marilou Santos y Tantay (“Malou”), were charged under the Comprehensive Dangerous Drugs Act of 2002 (R.A. No. 9165).
Two criminal cases were consolidated:

Criminal Case No. 11491-D for violation of Section 5 in relation to Section 26, Art. II, involving the sale, delivery, and giving away of dangerous drugs.
Criminal Case No. 11492-D (absorbing Criminal Case No. 11490-D) for violation of Section 11, Art. II, concerning also the possession and handling of dangerous drugs.

Originally, criminal informations were filed under the Dangerous Drugs Act of 1972 (R.A. No. 6425), but they were amended in view of the enactment of R.A. No. 9165.

On the early morning of July 5, 2002, a confidential informant notified the Pasig City Police Station regarding the alleged peddling of illegal drugs by the accused in Barangay Putol, Rosario, Pasig City.
The Station Drug Enforcement Unit, led by SPO4 Numeriano de Lara and assisted by SPO2 Dante Zigapan, PO2 Danilo Damasco (the designated poseur-buyer), PO1 Orig, and PO1 Bede Montefalcon, promptly organized an entrapment operation.

The informant identified the location and the accused.
The team deployed in two vehicles with specific assignments, ensuring separation between the poseur-buyer and the rest of the team.

PO2 Damasco, acting as the poseur-buyer, engaged with the accused.
Malou exchanged marked money (a P100 bill) for a plastic sachet containing a white crystalline substance.
Botong, having received the money from Malou, provided the sachet to her.
Following the exchange, the poseur-buyer signaled the team to arrest the accused.

The marked money was recovered.
Several plastic sachets containing the white crystalline substance, later confirmed as methamphetamine hydrochloride (shabu), and a sachet containing marijuana were confiscated.
The seized items were properly marked, processed through laboratory examination, and their identification was established by positive test results.

One testimony described that the accused, while sleeping in their rented apartment, were abruptly awakened by a loud noise that led to a confrontation with police officers.
In both narratives, the police conducted a search, which resulted in the recovery of the contraband items.

The accused tried to raise defenses including claims of illegal arrest, improper chain of custody for the seized drugs, denial of involvement, alleged frame-up, forcible entry, and extortion by the police.
It was noted that the accused had a history of prior cases, with one prior conviction and other cases pending, though this history was not sufficient to negate the evidence presented in the buy-bust operation.

Whether the accused-appellants are guilty beyond reasonable doubt for violating Sections 5 and 11 of Article II of R.A. No. 9165.

Allegation that the arrest was conducted illegally, rendering the seized evidentiary items inadmissible.
Claim that the chain of custody of the dangerous drugs was broken because the apprehending officers failed to make an inventory or photograph the items in the presence of the accused.
Assertion that the inconsistencies and contradictions in the testimonies of the prosecution witnesses undermine the prosecution’s case.
Statement that alternative defenses such as denial, claims of frame-up, and accusations of extortion by the police should have exonerated them.

Additional arguments on the chain of custody and failure of officer procedural requirements were considered new issues not raised in the appeal brief but only in the subsequent motion for reconsideration, and were consequently not entertained.