G.R. No. 198314 - People vs. Guinto y San Andres

The buy-bust operation was conducted on January 20, 2004, by the Anti-Illegal Drugs Special Task Force (AIDSTF) of the Pasig City Police Station.
The operation was initiated following information provided by a female informant about a person identified as “aCharda” supposedly selling shabu at 137 MC Guinto, Barangay Pinagbuhatan, Pasig City.
Team Supervisor SPO3 Leneal Matias coordinated with Police Inspector Melbert Esguerra to verify the information and subsequently planned the operation.

PO1 Mendoza received two pieces of marked P100.00 bills as buy-bust money from Police Inspector Esguerra.
The team, along with a civilian informant, proceeded to the target area around 11:00 p.m. on April 19, 2004 (noting later discrepancies in timing, as some testimonies mentioned 1:00 a.m.).
After waiting for a period (ranging from 15–20 minutes to two hours according to different testimonies), the suspect, later identified as Richard Guinto y San Andres, emerged from the house.

The informant approached Guinto, introducing PO1 Mendoza as a person needing illegal drugs worth P200.00.
PO1 Mendoza exchanged the marked money for shabu; Guinto provided plastic sachets containing the substance.
To signal the completion of the transaction, PO1 Mendoza used what was agreed to be a pre-arranged signal—stated by him as a raising of his hand, while another witness testified it was a scratching of the nape.
Following the signal, the rest of the team intervened and arrested Guinto.
PO1 Mendoza confiscated the marked money (with discrepancies noted on whether it was recovered from Guinto's left or right pocket) and marked the plastic sachet received.

The prosecution presented multiple police officers as witnesses, notably PO1 Mendoza, PO1 Familara, and PO2 Noble.
Testimonies revealed material inconsistencies:

Conflicting accounts on the number of plastic sachets involved (PO1 Mendoza testified two sachets while PO1 Familara testified one sachet).
Discrepancies in the description of the pre-arranged signal for confirming the transaction.
Different accounts regarding the time of arrival at the scene and the duration of waiting for the suspect’s emergence.
Contradictory statements on the source and location of recovery of the buy-bust money.

Forensic evidence was presented through the laboratory examination by Forensic Chemist Annalee R. Forro, which confirmed the presence of methamphetamine hydrochloride (shabu) in the confiscated sachet.

The accused, Richard Guinto y San Andres, denied involvement in an illegal drug sale, asserting that at the time of the alleged transaction he was at home cooking with his family.
Guinto claimed that armed men unlawfully entered his residence, conducted a search, and arrested him without proper identification or explanation.
His wife, Jane Guinto, and his son, John Mark Guinto, supported his version, highlighting inconsistencies in the police procedure and alleging irregularities such as extortion attempts at the police station.

Guinto was charged with Illegal Sale of Dangerous Drugs under Section 5, Article II of Republic Act No. 9165, specifically involving the sale of shabu.
At trial, despite his not-guilty plea, the Regional Trial Court convicted him beyond reasonable doubt on October 8, 2008, sentencing him to life imprisonment and imposing a fine of P500,000.00 along with accessory penalties.
The Court of Appeals affirmed the trial court’s decision, relying on the credibility of the police witnesses and the presumed regularity of the officers’ conduct during the operation.

On appeal, the Supreme Court scrutinized the evidentiary discrepancies, particularly the inconsistent testimonies regarding the identity of the corpus delicti (the plastic sachets of shabu).
The Court found that the conflicting statements of the police officers and the broken chain of custody undermined the prosecution’s evidence.
Consequently, the Supreme Court reversed and set aside the lower courts’ rulings, acquitting Guinto due to the reasonable doubt created by these inconsistencies.

Whether the prosecution was able to prove, beyond reasonable doubt, the identity and material aspects of the corpus delicti, particularly the number and identification of the plastic sachets containing shabu.
Whether the numerous inconsistencies in the testimonies of the police officers—regarding details such as the pre-arranged signal, timing of the operation, and recovery of the buy-bust money—created a reasonable doubt as to the proper execution of the buy-bust operation.
How the presumption of regularity in the performance of police duties should be weighed against the presumption of innocence, especially in light of conflicting and contradictory evidence impacting the credibility of the prosecution’s case.