G.R. No. 182790 - People vs. Cantalejo y Manlangit

An Information for violation of Section 5 of R.A. No. 9165 (Comprehensive Dangerous Drugs Act of 2002) was filed against Cesar Cantalejo y Manlangit.
At the arraignment, appellant pleaded not guilty, and trial on the merits commenced.
The prosecution presented two key police witnesses: PO2 Paul Acosta and PO1 Romualdo Cruda, along with other police assets involved in the buy-bust operation.
A police tip led to the organization of a buy-bust entrapment operation targeting a person identified as “Cesar” at Esteve Street, Manggahan, Commonwealth Avenue, Quezon City.

On January 20, 2004, past midnight, two police assets reported illicit drug activities involving a “Cesar” to the DPIU at Camp Karingal, Quezon City.
The police entrapment team was organized under the leadership of SPO4 Celso Jeresano with PO2 Paul Acosta acting as the designated poseur-buyer.
A P500.00 bill, marked by the poseur-buyer, was used as the buy-bust money.
The team, accompanied by additional officers (Antonio Disuanco, Genaro Martinez, Timoteo Evasco, Elmer Monsalve, Ramon Mateo, and Romualdo Cruda), proceeded by vehicle and on foot to the scene.
Upon arrival at Cesar’s residence, PO2 Acosta approached Cesar and initiated a conversation regarding the purchase of “pang gamit” (drugs) for P500.00, to which Cesar responded casually with “sandali lang”.
After collecting the money and receiving a plastic sachet (which PO2 Acosta examined and signaled by scratching his head), the police team executed the arrest.
The arrest further included the recovery of the plastic sachet, which was later sent to Camp Crame for forensic analysis, confirming the presence of shabu (methamphetamine).

Appellant and his wife, together with their five children, asserted that between 1:00 and 2:00 a.m. on January 20, 2004, they were inside their home sleeping.
They testified that a soft knocking, followed by a loud banging on the door, prompted Cesar to answer—and subsequently, several armed men entered while shouting “Dapa! Dapa!”.
Appellant complied with the orders given but denied the presence of shabu, insisting “wala pong shabu dito”.
The armed men conducted an hour-long warrantless search of the house, during which they allegedly disregarded the identity of the appellant and failed to establish any concrete link between him and the alleged drug transaction.
Nomeriano Belen, Jr. corroborated facts regarding the disturbance by testifying that he saw about ten (10) armed men near Cesar’s house.

The RTC of Quezon City, Branch 103, rendered a decision on April 28, 2006, convicting appellant on violation of Section 5, R.A. No. 9165.

The verdict found Cesar Cantalejo y Manlangit guilty beyond reasonable doubt of drug pushing.
The appellant was sentenced to life imprisonment and ordered to pay a fine of P500,000.00.
The plastic sachet involved was ordered to be transmitted to the PDEA for proper disposition.

The Court of Appeals affirmed this conviction on November 21, 2007, relying mainly on the testimonies of the buy-bust team and presuming the regularity in the conduct of police duties.

The prosecution’s case heavily relied on the police officers’ testimonies regarding the buy-bust operation, while the defense consistently maintained a frame-up theory.
Key issues arose regarding:

The credibility of the police accounts versus the defense’s version, which included testimonies regarding an unannounced and warrantless search.
The absence of rebuttal evidence by the prosecution concerning the defense’s assertions.

The chain of custody and proper inventory procedures for the confiscated drug (the plastic sachet) were called into question, with discrepancies noted in the handling and documentation of the evidence.

Whether the prosecution has met its burden to prove beyond reasonable doubt that a buy-bust operation actually occurred resulting in a drug sale transaction.

The conflict between the police officers’ version and the defense’s claim of a frame-up raises doubts.
Whether the absence of corroborative testimonies from additional police team members weakens the prosecution’s case.

Whether the constitutional presumption of innocence was effectively overruled by the evidence presented by the prosecution.

The court had to determine if the evidence sufficiently rebutted the presumption of innocence.
The lack of proper rebuttal evidence to counter the defense’s narrative is crucial.

Whether the search and seizure operations conducted at the appellant’s house violated constitutional provisions against unreasonable searches and seizures.

The manner in which the armed men entered, searched the house without a warrant, and intimidated the appellant and his family was scrutinized.
The issue of whether such irregularities should result in the exclusion or diminution of the probative value of the evidence gathered.

Whether the proper procedural requirements in the custody and disposition of the confiscated drugs (corpus delicti) under R.A. No. 9165 were observed.

Specifically, concerns were raised regarding the absence of a physical inventory, proper photographs, and an explanation for procedural lapses.
The failure to adhere to these protocols casts doubt on the integrity of the evidence.