G.R. No. 231839 - People vs. Arellano y Navarro

On April 18, 2013, in Laoag City, the accused-appellant, Michael Ryan Arellano y Navarro, was charged in three separate criminal cases for:

Illegal possession of three heat-sealed transparent plastic sachets containing shabu and four open sachets containing white residue believed to be shabu (Criminal Case No. 15491).
Illegal sale of shabu, evidenced by the transaction involving a plastic sachet weighing 0.1780 gram (Criminal Case No. 15492).
Illegal possession of drug paraphernalia (two folded aluminum foils) (Criminal Case No. 15493).

The charges were framed under Sections 5, 11, and 12 of Republic Act No. 9165 (Comprehensive Dangerous Acts Law of 2002).

A confidential informant tipped off the Provincial Anti-Illegal Drugs Special Operations Task Group (PAIDSOTG) regarding the accused’s drug activities.
At approximately 9:30 a.m. on April 18, 2013, a police team led by Action Officer P/Insp. Jeffrey Taccad organized a buy-bust operation:

The accused agreed to meet at a designated venue (initially a barangay in Bacarra, then shifted to Room 11 of Farmside Hotel in Laoag City).
PO3 Dalere was designated as a poseur-buyer and was given a P1,000 bill (marked with the initials “JMBD”) to effectuate the transaction.
Upon arrival, negotiations took place; the accused handed over a plastic sachet, allegedly containing shabu, and received the money in exchange.

Police officers, including PO2 Salacup, executed the arrest and conducted a body search, recovering the P1,000 and seizing various pieces of evidence.
Seized items included plastic sachets bearing markings “JMBD-1” through “JMBD-4”, additional sachets marked “JMBD-5” and “JMBD-7”, aluminum foils, and a lighter.
All evidence was documented through photographs, inventory certificates, and forwarded for forensic analysis by the PNP Crime Laboratory which confirmed the presence of Methamphetamine Hydrochloride (shabu).

The direct testimony of the poseur-buyer, PO3 Dalere, and corroborative statements by other officers.
The forensic chemistry report establishing the substances seized as shabu.

Denials of the charges and allegations of a “frame-up” by the police operatives.
His sole testimony, wherein he recounted being in Room 11 of the Farmside Hotel with a female companion at the time of the incident.
Alleged inconsistencies in the police officers’ testimonies, particularly regarding the presence and role of a female companion in the room.
Claims that irregularities in the conduct of the buy-bust operation, such as the admission of the female companion and the handling of seized evidence, cast doubt on the integrity of the prosecution’s case.

The Regional Trial Court (RTC) in Laoag City rendered a judgment on September 11, 2015:

The accused-appellant was convicted beyond reasonable doubt on all charges.
He was sentenced to imprisonment for illegal possession, sale, and possession of paraphernalia along with corresponding fines.

The CA endorsed the credibility of the police testimonies and the chain of custody of the evidence.
The CA found no compelling reason to deviate from the lower court’s factual determinations.

Accused-appellant, represented by the Public Attorney’s Office (PAO), filed an appeal contesting:

Alleged irregularities and inconsistencies in the police officers’ testimonies.
The overall integrity of the evidence, especially the issues concerning the presence and handling of the female companion in the hotel room.

The defense argued that these irregularities created a reasonable doubt as to the accused-appellant’s guilt.

Whether the prosecution’s evidence, including the testimonies of the police officers and the documentary evidence, established the accused-appellant’s guilt beyond reasonable doubt.
Whether the inconsistencies in the police officers’ testimonies—particularly those concerning the presence and role of the female companion in the room—undermine the credibility of the prosecution’s case.
Whether the presumption of regularity in the performance of police duties should prevail when there is evidence of irregularities that may support a frame-up defense.
Whether the chain of custody and handling of seized evidence were sufficiently reliable to meet the stringent requirements for convicting the accused-appellant for the crimes charged.