G.R. No. 47722 - People vs. Oanis

Ariel Calvelo y Consada was charged with violating Section 5, Article II of Republic Act No. 9165 for the illegal sale of shabu.
The charge arose from an alleged buy-bust operation conducted on November 26, 2005 at the Travelers’ Inn in Barangay Pagsawitan, Santa Cruz, Laguna.
The operation was carried out by law enforcement officers following a tip from a confidential informant regarding a drug deal.

A confidential informant first informed the Philippine Drug Enforcement Agency (PDEA) on November 25, 2005, that a deal for 15 grams of shabu worth P60,000 was in the works.
Regional Director Abe Lemos and team leader Police Chief Inspector Julius Ceasar Ablang held a briefing with members of the enforcement team, including Police Officer 2 (PO2) Marites T. Villanueva (assigned as poseur-buyer) and SPO2 Gerry Abalos (assigned as the back-up arresting officer), among others.
A pre-operation report was prepared after assessing the suitability of the Travelers’ Inn for the planned buy-bust.

On November 26, 2005, around 5:00 p.m., the informant contacted Ariel to confirm that a buyer was available; Ariel reportedly indicated that he was preparing the shabu.
The buy-bust team assembled and positioned two vehicles strategically—one with Villanueva and the informant (parked in front) and another with the rest of the team parked approximately 15 meters away.
At about 9:00 p.m., Ariel arrived on his red tricycle. The informant coordinated with him and signaled the meeting with Villanueva, who introduced herself as the buyer.
During the staged transaction, Villanueva showed a maroon pouch (purportedly containing payment) which actually held two marked P500 bills and additional boodle money.
After confirming the presence of money, Ariel delivered three transparent plastic sachets containing a total of 14.07 grams of shabu.
Villanueva signaled the successful consummation of the sale by turning on the hazard lights, prompting Abalos and other officers to storm the vehicle and arrest Ariel.

Immediately following the arrest, Villanueva marked each sachet with specific identifiers (Exh. “A” MTV 26/11/05, Exh. “B” MTV 26/11/05, and Exh. “C” MTV 26/11/05) and affixed her signature.
A certificate of inventory was prepared, listing all seized items including the drug specimens, the Kawasaki motorcycle with sidecar, and the marked currency.
The seized sachets were delivered to the PNP Regional Crime Laboratory Office 4, where a forensic examination confirmed the presence of methamphetamine hydrochloride (shabu).

Key witnesses PO2 Villanueva and SPO2 Abalos testified on the details of the buy-bust, including the identification of Ariel during the staged transaction.
The forensic chemist’s report confirmed that the specimens tested positive for shabu.
The chain of custody was extensively detailed, from initial marking to laboratory submission and eventual presentation in court.

Ariel testified that on the night of the operation he was closing a billiard hall at Barangay BiAan, Pagsanjan and subsequently went to the Travelers’ Inn to buy noodles for his brother, Jimmy.
According to Ariel, while waiting for his order he was accosted by five armed men, forcibly subdued, and later transported in a disorganized manner—events he claimed constituted an irregular arrest process.
His elder brother, Jimmy, corroborated the timeline – explaining Ariel’s errand to buy noodles and his subsequent disappearance.
Ariel contended that his arrest was the result of a frame-up, and he questioned the identity of the person who actually executed the drug purchase, asserting that the actual poseur-buyer might have been the informant and not Villanueva.

Whether the trial court gravely erred in giving full credence to the prosecution’s version of events despite alleged irregularities in the conduct of the buy-bust operation.

Whether the trial court erred in convicting Ariel on the ground that the prosecution failed to adequately establish the identity, integrity, and proper chain of custody of the seized drugs, which are critical to forming the corpus delicti.

Whether the trial court’s reliance on Villanueva’s testimony—as an eyewitness and poseur-buyer—was proper despite the defense’s argument that she was merely a bystander.
Whether the failure to present the informant as a witness was fatal to the prosecution’s case.