G.R. No. 209983 - Belarso vs. Quality House, Inc.

Case Digest (G.R. No. 209983)
Expanded Legal Reasoning Model

Facts:

Overview of the Case

The appellant, Ronnie Boy Eda y Casani, was charged for illegal possession and sale of methamphetamine hydrochloride (“shabu”) under Sections 11, Paragraph 2 (3) and 5, Article II of Republic Act No. 9165.
Two Informations were filed on February 18, 2011, in Criminal Cases Nos. 6604 (illegal possession) and 6605 (illegal sale).

Incident and Arrest

On February 17, 2011, at around 5:00 p.m. in Barangay Caloocan, Balayan, Batangas, a civilian asset tipped off the police regarding Eda’s sale of shabu.
Police Chief Inspector Elpidio Argoncillo Ramirez mobilized a buy-bust team consisting of PO2 Roman De Chavez Bejer, PO1 Reynante Brosas Briones, PO3 Bryan De Jesus, and other officers.
The team, along with the civilian asset, proceeded to the location where Eda was waiting near Balayan Cable Network.

Buy-Bust Operation and Seizure

During the operation:

PO2 Bejer, positioned inside a tricycle with the civilian asset, overheard the transaction as the asset agreed to purchase shabu for P500.00.
Eda exchanged a heat-sealed plastic sachet containing shabu (later marked “RCB-1”) for the marked money.

Upon witnessing the exchange, PO2 Bejer identified himself as a police officer and moved to arrest Eda.
A subsequent frisk conducted by PO1 Briones uncovered four additional plastic sachets in Eda’s right pocket, which were then recovered and marked “RCB-2” to “RCB-5.”
The seizure was documented:

Eda was informed of his constitutional rights and the confiscated items were logged.
A physical inventory was conducted at the Barangay Hall of Caloocan, attended by representatives of the Department of Justice, the barangay, and media personnel.
Photographs were taken, and an inventory receipt was duly signed.

Eda was then brought to the Balayan Police Station for further processing, including requests for drug tests and laboratory examinations.

Laboratory and Documentary Evidence

The seized drug specimens were tested by the Batangas Provincial Crime Laboratory.
Chemistry Report No. BD‑040‑2011 confirmed the presence of methamphetamine hydrochloride in the submitted specimens.
The chain-of-custody was maintained from the moment of seizure through inventory and laboratory examination, with each step corroborated by testimonies and documentary evidence.

Evidence Presented by the Prosecution

Multiple officers testified regarding the sequence of events:

PO2 Bejer detailed the pre-operation planning, the execution of the buy-bust, identification of the marked sachets, and recovery of the marked money.
PO1 Briones testified on discovering the additional four sachets and corroborated the markings placed by the team.

Documentary evidence such as the Pre-Operation Report, Coordination Sheet, marked money, inventory receipts, and photographs reinforced the physical evidence and testimonies.

Evidence and Arguments of the Defense

Eda denied the sale and possession of shabu, asserting he had never used the drug.
He claimed that on February 16, 2011, he was at his sister-in-law’s residence and spent the night drinking, which he argued provided him an alibi.
When confronted during the buy-bust operation:

He stated that four men, identified as “tulak” or pushers, accosted him.
He alleged that due to his inebriated state and the use of physical intimidation (including being hit, punched, and having a gun pointed at him), he succumbed to their accusation by saying “yes.”
Eda maintained that the shabu found on his person was planted by PO2 Bejer, rather than being his own.

His claims of a frame-up and the absence of any legal authority for possessing the drugs were raised as a defense.

Trial Court and Appellate Proceedings

On September 17, 2013, the Regional Trial Court (RTC) convicted Eda for both illegal sale and illegal possession of shabu.
The RTC’s decision was based on the solid chain-of-custody, the consistent testimonies of prosecution witnesses, and the authenticated documentary evidence.
The Court of Appeals (CA) later affirmed in toto the RTC decision in the December 10, 2014 ruling.
On appeal before the Supreme Court, Eda sought to overturn the convictions but repleaded with the same defenses, which were ultimately rejected.

Issues:

Sufficiency of Evidence

Whether the prosecution’s evidence established beyond reasonable doubt that Eda conducted the sale of shabu, including the identification of the drug, the marked money, and the presence of the buyer (civilian asset).
Whether the recovery of additional sachets from Eda’s person substantiated the charge of illegal possession.

Chain-of-Custody and Procedural Integrity

Whether the inventory, marking, physical custody, and laboratory examination of the seized drugs complied with the requirements under Section 21 of R.A. No. 9165.
Whether any alleged lapses in the chain-of-custody affected the evidentiary value of the seized drugs.

Credibility and Weight of Defense Evidence

Whether Eda’s defense of denial, frame-up, and claims of physical abuse were supported by clear and convincing evidence to rebut the presumption of regularity in police procedures.
Whether Eda adequately explained his possession of the drugs given the presumption of knowledge or animus possidendi.

Appropriateness of the Imposed Penalties

Whether the RTC’s imposed minimum and maximum periods of imprisonment and fines fell within the range provided by R.A. No. 9165.
Whether the application of the Indeterminate Sentence Law was correctly implemented in determining the prison term.

Ruling:

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Ratio:

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Doctrine:

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Case Digest (G.R. No. 209983) Core Legal Reasoning Model Expanded

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Case Digest (G.R. No. 209983) Expanded Legal Reasoning Model

Facts:

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Doctrine:

Case Digest (G.R. No. 209983)
Core Legal Reasoning Model

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Case Digest (G.R. No. 209983)
Expanded Legal Reasoning Model