Case Digest (G.R. No. 193661)
Facts:
People of the Philippines v. Ryan Blanco y Sangkula, G.R. No. 193661, August 14, 2013, the Supreme Court Second Division, Perez, J., writing for the Court. The plaintiff-appellee is the People of the Philippines; the accused-appellant is Ryan Blanco y Sangkula.On March 26, 2007 two Informations were filed against Blanco for acts allegedly committed on March 23, 2007 in Taguig City: Criminal Case No. 15537‑D‑TG for Sale of Dangerous Drugs (alleged sale of one 0.01‑gram sachet of shabu for Php100) in violation of Section 5, 1st paragraph, Article II of Republic Act No. 9165; and Criminal Case No. 15538‑D‑TG for Possession of Dangerous Drugs (alleged possession of six sachets totaling 0.06 gram) in violation of Section 11, 3rd paragraph, Article II of R.A. 9165.
The Regional Trial Court (RTC), Branch 267, Pasig City, conducted a joint trial after Blanco pleaded not guilty. The prosecution presented PO2 Renato Ibanez (poseur‑buyer) and PO3 Atanacio Allauigan (back‑up) who testified to a buy‑bust operation, the marked Php100 buy‑money, the confiscation of sachets and the submission of the items to the crime laboratory which tested positive for methylamphetamine hydrochloride. Blanco denied the charges and testified to his arrest under coercive circumstances and denied knowledge of the seized drugs.
On September 16, 2008 the RTC rendered a Joint Decision finding Blanco guilty of both illegal sale and illegal possession, sentencing him to life imprisonment and fines for the sale count and reclusion temporal (12 years + 1 day to 20 years) and fines for the possession count. The Court of Appeals, in CA‑G.R. CR‑HC No. 03624, affirmed the RTC Decision on May 24, 2010 with a modification stated as to the penalty in Criminal Case No. 15538‑D‑TG. Blanco appealed to the Supreme Court; his appeal concerned only the conviction fo...(Pro-only)
Issues:
- Was the prosecution able to prove beyond reasonable doubt the elements of illegal sale of a dangerous drug under R.A. 9165 against appellant Ryan Blanco?
- Do the alleged material inconsistencies in the prosecution witnesses' testimonies and the non‑presentation of the confidential informant vitiate the conviction for illegal sale?
- Was the buy‑bust operation and the arrest conducted by the police proper so a...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)