G.R. No. 252902 - People vs. Estabillo y Palara

Case Digest (G.R. No. 252902)
Expanded Legal Reasoning Model

Facts:

Background and Charges

Appellant SPO1 Alexander Estabillo y Palara was charged under two separate informations for violating Sections 5 and 11 of Republic Act No. 9165.
The charges involved:

Illegal sale (unauthorized trading/distribution) of dangerous drugs (cocaine)
Illegal possession of dangerous drugs

The separate criminal cases are identified as Criminal Case Nos. 17172-D-PSG (possession) and 17173-D-PSG (sale).

The Alleged Buy-Bust Operation and Arrest

A confidential informant reported that a police member known as “Alex” (later identified as appellant) was involved in drug activities including the possession of large quantities of cocaine.
Acting on the tip, the police conducted a test buy on June 14, 2010:

P/SSupt. Eduardo P. Acierto received the report.
P/Supt. Ismael G. Fajardo, Jr. and his team, including Police Inspector Jay James Nepomuceno, SPO2 Leonardo Taldo (designated as poseur-buyer), SPO3 Ngo, and PO3 Perida, were assigned to the operation.

On June 14, 2010, at a designated venue along Makati Avenue:

The confidential informant introduced SPO2 Taldo to “Alex” (the appellant).
Appellant stated the price for cocaine and agreed to transact; he initially provided a gram sample.

Subsequent Developments Leading to the Arrest:

SPO2 Taldo conducted a test buy which yielded a positive result for cocaine at the PNP Crime Laboratory.
On June 15, 2010, SPO2 Taldo was informed that four (4) kilos of cocaine were available.
Arrangements were made for a later meeting at Mercury Drugstore in Barangay Ugong, Pasig City, at 11 o’clock in the evening.
At around 9 o’clock in the evening, the operation took place:

Appellant arrived in a white and silver Mitsubishi Strada.
Inside the vehicle, he handed over a maroon-brown “Otto” shoebox containing two (2) bricks of suspected cocaine in exchange for a bag containing six (6) P500.00 bills and 60 bundles of boodle money dusted with ultraviolet powder.

After the transaction was signaled by SPO2 Taldo placing a call to SPO3 Ngo, members of the buy-bust team executed the arrest.
A subsequent search of the vehicle yielded another yellow Mario D’Boro box containing two (2) additional bricks of suspected cocaine.

Testimonies and Presentation of Evidence

Prosecution Witnesses:

Forensic Chemist PSI Mark Alain B. Ballesteros testified regarding the laboratory testing of the seized samples.
SPO2 Leonardo Taldo, SPO3 Ngo, and PO3 Lawrence Perida provided detailed accounts of the operation, including the marking and inventory of the seized items.

Defense Testimonies:

Appellant testified denying the charges.
His daughter, Carla Mendoza, and journalist Dennis Perillo (of GMA 7 News) testified from the defense’s perspective.

Handling and Marking of the Seized Items:

At the scene, the arresting officers immediately marked the two shoeboxes with distinct identifiers (e.g., LPP 06152315 2010, LPP1 06152315 2010, etc.) in the presence of witnesses such as Barangay Kagawad Santos and media representatives.
An inventory and photographic evidence were secured immediately after the arrest.
Later, the items were turned over through a series of custody transfers: from the arresting officers to the investigator (SPO3 Caluag), then to PCI Paul Ed C. Ortiz, and finally to PSI Ballesteros in the forensic laboratory.

Results of Laboratory Examination:

The four bricks of suspected cocaine were tested and confirmed positive for cocaine according to Chemistry Report No. D-43-10.

Procedural History

The Regional Trial Court (RTC), Branch 151, Pasig City rendered a decision on December 7, 2015:

Appellant was convicted on both counts (sale and possession).
The conviction included sentencing to life imprisonment and fines of Ten Million Pesos (₱10,000,000.00) for each offense.
The court also ordered the transfer of the dangerous drugs to the Philippine Drug Enforcement Agency (PDEA) for disposal.

On appeal, appellant raised several arguments against the trial court’s verdict and the legality of his arrest, including alleged irregularities during the seizure and inventory process.
The Court of Appeals, in its decision dated April 26, 2019, affirmed the trial court’s verdict and dismissed reconsideration on October 9, 2019.
Appellant’s supplemental brief reiterated his challenges, leading to the present appeal before the Supreme Court.

Issues:

Lawfulness of the Arrest

Whether the warrantless arrest of appellant was valid given that the arresting officers did not have personal knowledge of the contents of the shoebox.
Whether SPO2 Taldo’s call to SPO3 Ngo sufficed as a basis for probable cause to arrest the appellant.

Integrity of the Chain of Custody

Whether the prosecution established an unbroken and credible chain of custody for the seized items, despite issues such as:

The presence of a double laboratory examination request.
The absence of a representative from the Department of Justice (DOJ) during the inventory and marking of the seized items.

Whether the failure to perform an ocular inspection within 72 hours, as mandated by Section 21 of RA 9165, affects the evidentiary value of the seized cocaine.

Sufficiency of Evidence Concerning Transaction and Payment

Whether the delivery of boodle money dusted with ultraviolet powder and the lack of a positive test result for it weakens the element of the sale of dangerous drugs.

Adequacy of the Prosecution’s Presentation

Whether the prosecution sufficiently established all the elements of both illegal sale and illegal possession of dangerous drugs through credible witness testimonies and documented procedures.

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

Doctrine:

(Subscriber-Only)

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Case Digest (G.R. No. 252902) Core Legal Reasoning Model Expanded

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Case Digest (G.R. No. 252902) Expanded Legal Reasoning Model

Facts:

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Doctrine:

Case Digest (G.R. No. 252902)
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Case Digest (G.R. No. 252902)
Expanded Legal Reasoning Model