G.R. No. 143793 - People vs. Li Yin Chu

This case is an appeal from the May 18, 2000 decision of the Regional Trial Court (RTC) of Quezon City, Branch 95, Criminal Case No. Q-99-84942.
Appellant Li Yin Chu, also known as Robert Li, was convicted for violating Section 15 of Republic Act No. 6425 (as amended by RA No. 7659) for the illegal sale, delivery, and transport of a regulated drug (shabu).
The RTC sentenced him to reclusion perpetua and imposed a fine of ₱5,000,000.

The charge alleges that on July 4, 1999, in Quezon City, appellant sold, delivered, and transported a regulated amount of methylamphetamine hydrochloride (shabu) amounting to nine thousand eight hundred forty-nine point one grams using a blue Honda Civic (Plate No. WBY 852).
The operation was initiated following a report at the Service Support Office (SSO) of the Philippine National Police at Camp Crame; a tipster, claiming to be a long-time acquaintance of the appellant, informed on an imminent drug transaction.
The police organized a buy-bust operation where designated officers (including SPO1 Ludem delos Santos as the poseur-buyer, SPO1 Geronimo Pastrana, and others) were assigned roles to effect the arrest based on a pre-arranged signal during the transaction.

Police Senior Inspector Sonia Sahagun-Ludovico, the forensic chemist, who later testified that the substance seized tested positive for shabu.
SPO1 Ludem delos Santos, who acted as the poseur-buyer and testified that he met appellant, inspected the substance (from a self-sealing plastic bag inside the car), and signaled to his colleague for the arrest.
SPO1 Geronimo Pastrana, who corroborated the sequence of events in the buy-bust operation.

A detailed laboratory report confirming the drug’s identity as methylamphetamine hydrochloride.
The seizure of the regulated drug from appellant’s vehicle during the operation.

Appellant’s narrative and defense witnesses (including Jose Co and his own testimony) contended that:

He was contacted by an unidentified Chinese caller regarding a business proposition and went to the meeting place for that purpose.
The individuals who arrested him were in civilian attire, and he was taken by surprise, even claiming to have been slapped and beaten.

The buy-bust operation details were irregular, arguing that the absence of a simultaneous exchange of money did not validate the sale.
The arrest was unlawful, and the police allegedly engaged in a frame-up, extorting money (stated as ₱5 million) and beating him, actions he contended undermined his constitutional rights.
That his inability to speak Tagalog or English resulted in a misunderstanding during the transaction and subsequent arrest.

The defense maintained that the conduct of the police, including discrepancies in the operational paperwork (e.g., issues with the buy-bust money receipts and the operational coordinating sheet), further supported his claims of irregularity.

The confidential informer and the poseur-buyer coordinated with the police, and a pre-arranged signal was given by Delos Santos to effect the arrest.
Although there was an issue regarding the non-simultaneous presentation of the buy-bust money, the prosecution argued that such irregularity did not negate the consummated sale.

Appellant was promptly read his constitutional rights, despite language barriers, with the assistance of the informer.
Confiscation of both the shabu and the vehicle occurred immediately after the arrest, with the drug subsequently subjected to laboratory examination.

Whether the evidence presented by the prosecution, particularly the testimony of the poseur-buyer and the forensic laboratory report, is sufficient to prove appellant’s guilt beyond reasonable doubt.
Whether the absence of a simultaneous exchange of buy-bust money undermines the prosecution’s claim that a sale occurred.

Whether the arrest of the appellant was unlawful or irregular due to alleged non-compliance with standard operating procedures in conducting buy-bust operations.
Whether the alleged discrepancies (e.g., issues with receipt numbers and operational paperwork) are material enough to vitiate the presumption of regularity in police operations.

Whether the trial court erred in giving high credibility to the prosecution witnesses, especially SPO1 Ludem delos Santos, over the conflicting accounts and defenses provided by the appellant.
Whether the frame-up defense, including claims of extortion and physical abuse by the police, has any substantial evidentiary basis.

Whether appellant’s right to be fully informed of the specific acts constituting the offense was compromised, particularly in relation to the content of the Information filed against him.