G.R. No. 131856-57 - People vs. Montinola

Two Informations were filed before the Regional Trial Court (RTC) of Balanga City, Branch 92.
Accused-appellant Christian Dela Cruz y Dayo was charged in Criminal Case No. 15233 for Illegal Sale of Dangerous Drugs under Section 5, Article II of RA 9165.
Accused-appellant Arsenio Forbes y Dayo was charged in Criminal Case No. 15234 for Illegal Possession of Dangerous Drugs under Section 11, Article II of RA 9165.

On October 6, 2015, at around 5:00 p.m., after a successful operation by the Balanga City Police Station against Gil Obordo, the latter received a cellphone call from a “person named Intan” later identified as Dela Cruz.
Following Obordo’s confession that Dela Cruz was his supplier, the police orchestrated an entrapment operation using PO1 Michael Disono as a poseur-buyer.
Approximately two and a half hours later at the designated meeting place, Dela Cruz arrived riding a motorcycle, accompanied by a companion later identified as Forbes.
At the scene, Dela Cruz handed over a sachet containing a white crystalline substance to Forbes, remarking, “Ito, para hindi ka mainip,” before proceeding to meet with PO1 Disono to consummate the drug transaction.
The buy-bust team promptly intervened; Dela Cruz was arrested in flagrante delicto during the drug sale, and Forbes was apprehended after PO1 Disono observed him receiving the sachet.
A frisk on Forbes led to the recovery of a plastic sachet containing the white crystalline substance from his right pocket.

Immediately after arrest, the buy-bust team marked the seized items (plastic sachets) at the scene.
The items were transported to the police station where an inventory, physical examination, and photography were conducted in the presence of Barangay Kagawad Armando S. Zabala and a DOJ Representative, Villamor Sanchez, in compliance with prescribed procedures.
The seized items were subsequently forwarded to the crime laboratory where tests confirmed the presence of methamphetamine hydrochloride (shabu), quantifying 0.0811 gram and 0.0736 gram, respectively.
The entire process upheld the chain of custody protocol as mandated by RA 9165 and its amendment via RA 10640.

Dela Cruz claimed that on the day of the arrest he was en route home when he was suddenly flagged down by unidentified men in civilian clothes, who allegedly forced him into a car, detaining him at a safe house before transporting him to the police station where he was coerced into signing a document “for his protection.”
Forbes asserted that he was waiting for his live-in partner when he was abducted by three men in civilian vehicles, taken first to a safe house where he was beaten and forced to drink a glass of water, and eventually brought to the police station where he encountered his cousin Dela Cruz.
The court found these defenses to be uncorroborated and self-serving, lacking evidence to contest the physical and documentary proof obtained by the police.

Dela Cruz was found guilty beyond reasonable doubt of the crime of Illegal Sale of Dangerous Drugs, imposing life imprisonment and a fine of P500,000.00.
Forbes was found guilty beyond reasonable doubt of the crime of Illegal Possession of Dangerous Drugs, sentencing him to a term of imprisonment ranging from twelve (12) years and one (1) day to a maximum of fifteen (15) years, along with a fine of P300,000.00.

The Court of Appeals (CA), in its Decision dated November 27, 2017, affirmed the RTC decisions, upholding both convictions and noting proper compliance with evidentiary requirements and the chain of custody rules.

Both accused-appellants appealed the RTC decision, arguing issues regarding the integrity of the evidence and allegations of a frame-up.
The Supreme Court, in its review, addressed these contentions while focusing on the legal and procedural soundness of the lower court determinations.

Was there adequate evidence to establish that Dela Cruz sold a sachet containing shabu during the legitimate buy-bust operation?
Did the evidence clearly show that Forbes was in possession of a sachet containing shabu, having freely and consciously received it from Dela Cruz?

Was the chain of custody properly maintained from the moment of seizure at the scene to the presentation of the evidence in court?
Did the procedures of marking, inventory, and photography conform to the witness requirements mandated by RA 10640 as amended?

Did the accounts of Dela Cruz and Forbes regarding their alleged abduction and subsequent treatment have any corroborative evidence to support claims of frame-up?
Were the alternative narratives sufficient to create reasonable doubt against the prosecution’s version of events?

Was the trial court proper in relying on the testimony of law enforcement officers involved in the operation?
Did the trial court have the authority to evaluate the credibility of the witnesses and the supportive physical evidence without resorting to appellate intervention?