G.R. No. 205741 - People vs. Endaya y Laig

Appellant, Reyman Endaya y Laig, was charged under two separate informations filed before the RTC of Lipa City, Branch 12.
Criminal Case No. 0098-2003 pertained to illegal possession of dangerous drugs (Section 11, Article II of R.A. No. 9165), involving the recovery of eight (8) small heat-sealed transparent plastic sachets containing methamphetamine hydrochloride (shabu) weighing a total of 0.32 gram.
Criminal Case No. 0099-2003 pertained to the illegal sale of dangerous drugs (Section 5, Article II of R.A. No. 9165), alleging that the appellant sold one (1) plastic sachet containing shabu weighing 0.04 gram.

On November 11, 2002, police operatives of the Mataasnakahoy Police Station initiated surveillance after receiving a report from a barangay official that the appellant was involved in drug activities.
A week-long surveillance confirmed the veracity of the report.

On November 20, 2002, at about 7:00 o’clock in the evening, a team composed of SPO4 Moriel Benedicto, SPO3 Nestor Babadilla, and PO2 Edwin Chavez, along with a civilian asset acting as the poseur-buyer with marked money, embarked on a buy-bust operation.
The operation was conducted at the Golden Luck Beer Garden in Barangay 2-A, Mataasnakahoy, Batangas.
The civilian asset positioned himself outside the establishment and engaged with the appellant, who was a regular customer.
During the encounter, the asset handed marked money (five pieces of P100.00 bills) to the appellant, who in turn handed over a plastic sachet containing shabu.
A pre-arranged signal (the asset touching his head) confirmed the completion of the transaction.

After the transaction, the police officers immediately approached the appellant, identified themselves, and informed him of his arrest for selling shabu.
The appellant was informed of his constitutional rights in Tagalog.
A frisk was conducted, during which SPO3 Babadilla recovered the marked money from the appellant.
The plastic sachet involved in the sale was handed over to PO2 Chavez who marked it distinctively by burning its edges.
A subsequent body search at the police station revealed an additional eight (8) sachets of shabu in the appellant’s wallet, which were also marked by PO2 Chavez.

Immediately after the seizure, a detailed inventory of the confiscated items was taken in the presence of multiple witnesses including a Clerk of Court, a municipal counselor, a barangay captain, an NGO representative, members of the Sangguniang Bayan, and a media representative.
A photograph including the appellant and the seized items was taken at the police station.
The marked sachets were forwarded within 24 hours to the Philippine National Police crime laboratory, where the qualitative examination yielded a positive result for methamphetamine hydrochloride (shabu).

The appellant denied involvement in drug-related activities, asserting that at the time of the incident he was at home watching TV with his family in Barangay Nangkaan.
He claimed that around 9:00 o’clock he went with a friend to Lipa City and then to the Golden Luck Beer Garden.
According to his version, when approached by SPO4 Benedicto inside the establishment, he was invited to accompany the police to their car.

The appellant alleged that SPO4 Benedicto punched him in the stomach and forced him into the police car.
He claimed that the police officers attempted to extort information by threatening his life if he did not name a drug pusher.
He maintained that during transport and at the police station, further physical abuse was committed, including an additional punch by a police officer.
The appellant stated that his wallet was taken and left in the car by SPO3 Babadilla.
He also contested that he was forced to sign the inventory receipt for the seized items without the aid of counsel and without being allowed to read its contents.

The appellant contended that he did not file any case against the police due to his incarceration and his claimed ignorance of legal procedures.

The seized sachets were marked by PO2 Chavez with an identifying figure (a8a) and, in the case of the sachet sold during the buy-bust, also burned at the edges to distinguish it.
The chain of custody was maintained through physical inventory and photographic documentation, supported by the signatures of diverse official and non-government observers.

The specimens sent for laboratory examination tested positive for shabu, thereby confirming the identity of the corpus delicti.

The apprehending team complied with the required procedures by inventorying and photographing the seized items, which is a safeguard to preserve the integrity of evidence.

The appellant claimed that the lower court erroneously convicted him for violations of Sections 5 and 11 of R.A. No. 9165 despite the prosecution’s alleged failure to establish his guilt beyond reasonable doubt.
He argued that his constitutional rights were violated when he was forced to sign the Receipt for Property Seized without the assistance of counsel, contending that such signature should be inadmissible as evidence.
The appellant further contended that the plastic sachets of shabu should be excluded as evidence on the ground that they were the fruits of a “poisonous tree” obtained through an unlawful arrest and search.