Case Digest (G.R. No. 179710) Core Legal Reasoning Model
Facts:
The case involves Aldrin Berdadero y Armamento (appellant) as the accused in a criminal case known as Criminal Case No. 12861, which was filed on March 28, 2003. The appellant was charged with the violation of Section 5, Article II of Republic Act No. 9165 (the Comprehensive Dangerous Drugs Act of 2002). The accusation stated that on March 25, 2003, around 2:40 PM at Arrieta Subdivision, Barangay 20 in Batangas City, he unlawfully sold 0.04 grams of shabu (methamphetamine hydrochloride) without the authorization of law.
During the trial, the prosecution and defense offered contrasting narratives surrounding the events leading to the appellant's arrest. The prosecution's version indicated that the police operatives received a tip about the appellant's drug sales, leading to a buy-bust operation with a designated informant as the poseur-buyer. After a successful transaction where the appellant allegedly sold two sachets of shabu in exchange for marked money, he was a
Case Digest (G.R. No. 179710) Expanded Legal Reasoning Model
Facts:
- Factual Background and Allegations
- On March 28, 2003, an Information was filed against appellant Aldrin Berdadero y Armamento for violating Section 5, Article II of Republic Act (RA) No. 9165. The case was docketed as Criminal Case No. 12861.
- The Information alleged that on March 25, 2003, at about 2:40 p.m., at Arrieta Subdivision (Brgy. 20), Batangas City, the appellant unlawfully sold, dispensed, or delivered 0.04 gram of shabu (methamphetamine hydrochloride) in violation of the law.
- At arraignment, the appellant pleaded not guilty, setting the stage for conflicting accounts during the trial.
- Versions of the Incident
- The Prosecution’s Account
- The Batangas City Police Station’s Investigation Section received a report from an informant alleging that the appellant was selling shabu.
- PO3 Danilo F. Balmes and PO2 Edwalberto M. Villas organized a buy-bust operation, designating the informant as the poseur-buyer.
- The police officers and the informant went to the target area and parked the van in front of the appellant’s residence.
- The informant engaged the appellant in conversation; after the appellant went inside his house and later returned, he handed over two plastic sachets containing a white crystalline substance in exchange for marked money.
- Following the pre-arranged signal from the informant that the sale was consummated, police officers apprehended the appellant, recovered the money, and recorded the incident in the barangay hall blotter.
- The plastic sachets were marked (DFB-1 and DFB-2) by PO3 Balmes and later submitted for laboratory examination which confirmed the substance as shabu.
- The Defense’s Account
- The appellant claimed he was a victim of a frame-up.
- He testified that two men posing as locksmiths visited his house at around 2:40 p.m. on March 25, 2003.
- According to his version, after initially being allowed entry by his mother, the men returned, forcibly entered by kicking the door, and apprehended him without any clear explanation.
- The appellant denied that any illicit drugs were recovered from him and disputed that the arresting individuals were the police officers PO3 Balmes and PO2 Villas.
- Procedural History
- The Regional Trial Court (RTC) of Batangas City, Branch 4, rendered its decision on October 10, 2005, convicting the appellant and sentencing him to life imprisonment and a fine of P500,000.00.
- The decision included the confiscation of the shabu, which was examined and confirmed by a crime laboratory.
- Dissatisfied with the RTC’s decision, the appellant filed an appeal before the Court of Appeals (CA), which, on July 3, 2007, denied the appeal for lack of merit and affirmed the trial court’s ruling.
Issues:
- Whether the trial court erred in disregarding the evidence and alternative account presented by the defense regarding the alleged frame-up and the events during the arrest.
- Whether, assuming the prosecution’s version of the buy-bust operation is true, the trial court committed error in convicting the appellant beyond reasonable doubt on the basis of the evidence presented.
- Whether the alleged non-compliance with Section 21 of RA 9165 regarding the physical inventory and photographic documentation of the seized drugs affects the validity of the chain of custody, considering the justifiable grounds provided by the apprehending officers.
- Whether the absence of the poseur-buyer as a witness or the contention regarding the authority of PO3 Balmes and PO2 Villas (and the issue of PDEA involvement) undermines the prosecution’s case.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)