G.R. No. 195777 - People vs. Castro y Lapena

The accused-appellant, Ferdinand Castro y Lapena, was charged for violations of Sections 5 and 11 of Republic Act No. 9165 (the Dangerous Drugs Act of 2002) for illegal sale and illegal possession of methamphetamine hydrochloride (“shabu”).
At the Regional Trial Court of Pasig City, the accused pleaded “not guilty” and was subsequently convicted beyond reasonable doubt for the crimes charged.
The Court of Appeals affirmed the conviction with modifications—upholding the trial court’s findings while adjusting the penalty for illegal possession—and denied the motion for reconsideration.

On May 7, 2003, during a buy-bust operation coordinated by members of the Pasig City Police, a confidential informant tipped off the police that a person identified as “Fredie” (later identified as the accused-appellant) was selling illegal drugs at Kalamansi Street, Barangay Manggahan, Pasig City.
A dedicated buy-bust team was organized, which included PO1 Allan Mapula (the designated poseur-buyer) and PO1 Michael Familara, along with other police personnel and coordination with the Philippine Drugs Enforcement Agency (PDEA).
The operation was prearranged with signals and a pre-marked hundred-peso note used as the buy-bust money.

The informant introduced PO1 Mapula to the accused-appellant as a buyer of shabu.

During their interaction, the accused-appellant acknowledged the transaction by accepting the marked 100-peso bill and handing over a plastic sachet containing a white crystalline substance.
PO1 Mapula signaled to the buy-bust team by putting on his cap, thereby indicating that the sale had been consummated.

Following the transaction, the arresting officers, including PO1 Familara, immediately detained the accused-appellant.

While at the scene, during the officer-led frisk, three plastic sachets were discovered in the accused-appellant’s possession.
Out of the three sachets, one was directly involved in the transaction (marked “AVM/FLC 05/08/03”), and the other two were marked by the officers (“MRF” and “FLC”) upon search.

The marked plastic sachets allegedly containing shabu.
The marked buy-bust money which was used to effect the transaction.
The forensic examination report (Forensic Chemistry Report No. D-849-03E) which confirmed the presence of methamphetamine hydrochloride.

The evidentiary process was verified by the duly executed Request for Laboratory Examination and proper handling by the PNP Crime Laboratory, thus establishing a continuous chain of custody.

The chain of evidentiary custody was defective.
The testimonies of both the prosecution and defense witnesses were self-serving, suggesting that the equipoise rule should have favored the accused.
The arrest, which was allegedly made without a proper warrant, was invalid, and the seized items were inadmissible.

The defense’s narrative differed from the prosecution by alleging that the arrest took place outside the accused’s house during a drinking spree with friends, rather than during a coordinated police operation.

Whether the prosecution sufficiently established beyond reasonable doubt the elements of illegal sale and illegal possession of dangerous drugs, including the identities of the buyer and seller, the object of sale, and the payment for such sale.
Whether the chain of custody of the seized plastic sachets was credibly maintained as required to authenticate the evidence presented at trial.
Whether the credibility and consistency of the prosecution witnesses, particularly those from the buy-bust team, outweigh the contradictory testimony of the defense and its witnesses regarding the circumstances of the arrest.
Whether the application of the equipoise rule in favor of the accused is justified when the testimonies of the prosecution witnesses are corroborated by physical evidence and laboratory findings.
Whether the alleged warrantless arrest and the subsequent seizure of evidence can be decisively deemed unlawful, thereby affecting the admissibility of the evidence.