G.R. No. 229828 - People vs. Juguilon y Ebrada

The case involves the People of the Philippines charging Elsie Juguilon y Ebrada with the violation of Section 5 (Illegal Sale of Shabu) under Article II of Republic Act (RA) No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002.
The offense allegedly occurred on February 20, 2007, in Cebu City during a buy-bust operation conducted by the Philippine Drug Enforcement Agency (PDEA).

The PDEA received information that the appellant was actively engaged in the illegal drug trade in Barangay Carreta, Cebu City.
Regional Director Amado E. Marquez, Jr. assigned the verification of the report which entailed a three-day surveillance of the suspected location.
An informant (the appellant’s errand boy) volunteered to assist and later indicated that the appellant possessed shabu and was willing to transact at a specified rendezvous point near the Cebu Health Office.

At about 1:00 p.m. on the designated day, PO2 Rey Robert S. Villarete, acting as the poseur-buyer with a marked P500 bill, met the appellant following the tip-off from the informant.
During the encounter, PO2 Villarete inquired about the price and quantity of the shabu, to which the appellant quoted a price of P20,000.00 per “bulto” (approximately five grams).
A transaction took place wherein the appellant handed over two heat-sealed, transparent plastic packs containing a total net weight of 48.65 grams of shabu in exchange for the marked money.

Immediately after the transaction, PO2 Villarete signaled the completion of the deal and identified himself as a PDEA operative, prompting the warrantless arrest of the appellant in flagrante delicto.
The arrested appellant, along with her daughter and an accompanying family member, was taken to the PDEA Office.
At the PDEA Office, the seized items were promptly marked with identifiers (“EJ-02-20-07 1” and “EJ-02-20-07 2”), inventoried, and photographed in the presence of multiple witnesses, including a media representative and public officials.
A laboratory examination of the seized items by Forensic Chemist Jude Daniel M. Mendoza confirmed the presence of methamphetamine hydrochloride (shabu).

At the trial on the merits, the appellant pleaded not guilty and raised defenses including denial, alibi, and allegations of a frame-up.
The Regional Trial Court (RTC) found the appellant guilty of the illegal sale of shabu, basing its findings on the credible testimonies of the arresting officers and the established chain of custody of the seized drugs.
The RTC sentenced the appellant to life imprisonment, imposed a fine of P500,000.00, and ordered the forfeiture of the shabu for government disposal.

The appellant subsequently appealed the RTC decision to the Court of Appeals (CA), which upheld her conviction.
The CA affirmed that the essential elements of the crime were established and that the buy-bust operation, warrantless arrest, and chain of custody were all legally executed.
Issues raised by the appellant regarding the lack of prior surveillance, the specifics of the marked money, and the absence of the informant’s direct testimony were rejected as unmeritorious by the CA.
Following the denial of her motion for reconsideration, the appellant elevated the case further, though the higher court eventually dismissed the appeal, affirming the decisions of the lower courts.

Was the buy-bust operation conducted in conformity with legal standards, including the adequacy of surveillance and the role of the informant?
Did the use of marked money and the procedural handling of the transaction meet evidentiary requirements?

Was the warrantless arrest justified under the doctrine of in flagrante delicto as provided by Section 5(a), Rule 113 of the Rules of Court?
Was the subsequent seizure and search of the drugs legally valid given the circumstances of the arrest?

Has the prosecution adequately established the essential elements of the illegal sale of dangerous drugs, particularly the identification of buyer and seller, the object of sale, and the delivery/payment process?
Does the presentation of the seized drugs as corpus delicti sufficiently corroborate the occurrence of the illicit transaction?

Were the procedures for marking, inventorying, and photographing the seized items executed in accordance with Section 21 of RA 9165 and its Implementing Rules and Regulations?
Did any alleged deviations in the chain of custody or in the conduct of the inventory process affect the admissibility and integrity of the evidence?

Do the defenses of denial, alibi, and frame-up, as raised by the appellant, have sufficient merit against the concrete evidence presented?
Does the appellant’s contention regarding the alleged deficiencies in the operation (e.g., absence of prior surveillance and non-presentation of certain evidentiary elements) undermine the prosecution’s case?