G.R. No. 175281 - People vs. Evangelista

In an Information dated 15 December 2000, Reyes and appellant Evangelista were charged with violating Section 15, Article III of Republic Act No. 6425 (Dangerous Drugs Act of 1972, as amended) for allegedly selling 974.12 grams of methylamphetamine hydrochloride (shabu) in Quezon City.
Upon arraignment, both Reyes and Evangelista pleaded not guilty, contesting their involvement and asserting defenses of denial, alibi, and framing.

A female informant notified the police at around 3:00 p.m. on 13 December 2000 that a person—later identified as Vincent Evangelista (“Bong”)—and another person, Raymundo Reyes (“Reyes”), were seeking a buyer for illegal drugs.
Based on the informant’s tip, Lt. Joy Anrade organized a buy-bust team including SPO2 Celestino Dela Cruz (poseur-buyer), PO2 Rolando Tizon, and PO2 Jorge Izon as back-up, with pre-arranged arrangements for the buy-bust payment which consisted of genuine P1,000.00 and P500.00 bills, some of which were marked.

At approximately 9:00 p.m. on the day in question, the informant and the police team proceeded to the Shell Gasoline Station at Timog Avenue, Quezon City, where the operation was set to take place.
Appellant Evangelista arrived at the scene and requested the money for the purchase; upon entry of Reyes (who fetched a small red box alleged to contain the shabu), SPO2 Dela Cruz examined the contents and, based on his expertise, confirmed the presence of shabu.
Following the exchange of the buy-bust money and the delivery of the illegal drug, the police team, using a coordinated signal, arrested the accused.

The seized substance was subsequently subjected to chemical analysis, which confirmed its identity as methylamphetamine hydrochloride weighing 974.12 grams.
SPO2 Dela Cruz testified in detail about the transaction—from the initial contact made through the informant, the arrangement of payment, the handling of the drugs, to the subsequent arrest—and his testimony was corroborated by the laboratory report.
The only prosecution witness was SPO2 Dela Cruz. The defense’s attempt to discredit his testimony by pointing to inconsistencies, particularly regarding who received the marked money, was countered during cross-examination, where any apparent discrepancy was clarified.

Reyes and Evangelista claimed they were being framed and that they did not know each other prior to the incident.
Reyes asserted an alibi by testifying that he had been in a hotel (Sir William Apartelle, Quezon City) after receiving a phone call from Rose Lameseria regarding a job interview, and he was later arrested when unidentified armed men entered the room.
The defense presented a hotel night manager, George Dumlao, who refuted Reyes’ account by indicating that hotel records did not show any registration of Reyes or any related incident.
Evangelista’s alibi involved his claim of dining at a nearby food plaza around 9:15 p.m. before being forcibly removed from his car by armed men; this account was undermined by the improbability of traveling from Caloocan to Quezon City solely for a meal, as well as his inability to recall details of the establishment.

The trial court (RTC, Quezon City, Branch 103) rendered a judgment on 14 December 2001, finding both Reyes and Evangelista guilty beyond reasonable doubt and sentencing them to reclusion perpetua and a fine of P500,000.00 each.
The Court of Appeals, in a decision on 14 July 2006 (and subsequent resolution on 3 November 2006), affirmed the trial court’s decision in toto.
Following the denial of a motion for reconsideration by the Court of Appeals, Evangelista filed a petition for review under Rule 45 before the Supreme Court on 8 December 2006.

Whether the sole testimony of SPO2 Dela Cruz, as presented by the prosecution, was sufficient to establish the guilt of the accused beyond reasonable doubt.
The credibility of the witness and the impact of any alleged discrepancies in his testimony on the overall case.

Whether the procedures followed during the buy-bust operation, including the handling of the transaction details, met the requirements of the so-called “objective test” in entrapment and buy-bust operations.
Whether there was any evidence suggesting that the police conduct or motive was improper, potentially invalidating the operation.

Whether the defenses asserting that the accused were framed or that their alibis were credible had sufficient evidentiary basis to raise reasonable doubt about their participation in the alleged sale of shabu.