Title
People vs. Manlangit y Tresballes
Case
G.R. No. 189806
Decision Date
Jan 12, 2011
Manlangit convicted for selling and using shabu after a valid buy-bust operation; SC upheld conviction despite procedural lapses, citing unbroken chain of custody.

Case Digest (G.R. No. 189806)
Expanded Legal Reasoning Model

Facts:

  • Procedural History
    • The case is an appeal from the August 28, 2009 Decision of the Court of Appeals (CA) in CA-G.R. CR-H.C. No. 03273, which fully affirmed the Regional Trial Court’s (RTC) Decision dated July 12, 2007.
    • The RTC, Branch 64 in Makati City, found accused-appellant Francisco Manlangit y Tresballes guilty of two offenses under RA 9165:
      • Violation of Section 5, Article II (drug-sale)
      • Violation of Section 15, Article II (drug-use)
    • The CA’s affirmation and subsequent denial of the appeal form the backdrop of the present decision.
  • Filing of the Information and Charges
    • On November 25, 2003, an information was filed charging Manlangit with drug-sale:
      • Allegation that on or about November 24, 2003, in Makati City, without lawful authorization, he sold, gave away, distributed, and delivered 0.04 gram of shabu (Methylamphetamine Hydrochloride).
    • On December 11, 2003, a separate information was filed charging Manlangit with drug-use:
      • Allegation that, before or on November 24, 2003, he unlawfully used Methylamphetamine after a confirmatory drug test had shown him positive.
  • The Trial and Prosecution Evidence
    • During arraignment in both cases, Manlangit pleaded not guilty, and the cases were tried jointly.
    • The prosecution presented evidence garnered from a coordinated buy-bust operation conducted by:
      • The Makati Anti-Drug Abuse Council (MADAC) Cluster 4 office, along with the Anti-Illegal Drugs Special Operations Task Force (AIDSTOF) and the Philippine Drug Enforcement Agency.
      • Officers including Police Officer 2 Virginio Costa (team leader), MADAC operative Wilfredo Serrano (poseur-buyer), and Roberto Bayona (back-up).
    • Operation Details:
      • An informant provided a tip-off that a “Negro” was selling prohibited drugs on Col. Santos Street, Brgy. South Cembo, Makati City.
      • The team, with pre-arranged marked money, observed Manlangit near his residence.
      • Acting on the informant’s guidance, Serrano engaged Manlangit in a transaction for PhP 200 worth of shabu.
      • Manlangit emerged with a plastic sachet containing a white crystalline substance which he handed over in exchange for the marked money.
      • A signal (lighting a cigarette) indicated to the team that the operation was complete, after which Manlangit was arrested in flagrante delicto.
    • Post-Arrest Evidence Handling:
      • The marked money was recovered from Manlangit’s pocket.
      • The plastic sachet was marked, sent to the Philippine National Police (PNP) crime laboratory where it was positively identified as Methylamphetamine Hydrochloride (Chemistry Report No. D-1190-03).
      • A drug test conducted on Manlangit also yielded a positive result for Methylamphetamine.
  • Accused-Appellant’s Version and Allegations
    • Manlangit denied the occurrence of the buy-bust operation and asserted the recovered shabu was not his.
    • He claimed that he was identified to the operatives by a certain Eli Ballesteros rather than being an active participant.
    • Allegations were made regarding:
      • Detention at the Barangay Hall of Brgy. Pitogo
      • Interrogation involving physical abuse (e.g., being “boxed in the chest”)
      • Procedural lapses including the absence of a search warrant and noncompliance with the custody and control procedures for seized items under RA 9165.
  • Judicial Decisions at Trial and Appellate Levels
    • RTC Decision (July 12, 2007):
      • Found Manlangit guilty of drug-sale (life imprisonment and a P500,000.00 fine) and drug-use (rehabilitation for at least six months).
      • Ordered the plastic sachet containing shabu be transmitted to the PDEA for further action.
    • CA Decision (August 28, 2009):
      • Affirmed the RTC’s decision and held that:
        • No prior surveillance is necessary for a valid buy-bust operation if conducted in the presence of an informant.
ii. The warrantless arrest of Manlangit was justified as he was caught in flagrante delicto. iii. The chain of evidence was maintained and the testimonies of the operatives, which were credible, supported the conviction.

Issues:

  • Whether the prosecution failed to establish beyond reasonable doubt the guilt of accused-appellant for the crime of drug-sale and drug-use.
    • The accused argued that the evidence did not conclusively prove his participation in the transaction.
    • He contended that his mere denial, without substantial supporting evidence, should create reasonable doubt.
  • Whether the procedural requirements for the custody and control of seized dangerous drugs, specifically under Section 21 of RA 9165, were complied with.
    • The accused claimed that the buy-bust team failed to:
      • Conduct a proper inventory and photograph the seized sachet on site.
      • Carry out these procedures in the presence of the accused, his counsel, a media representative, or an elected official.
    • The contention focused on whether such lapses rendered the chain of custody defective.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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