G.R. No. 174773 - People vs. Miranda y Rama

On January 12, 2004, at around 7:00 PM in Barangay Calitlitan, Municipality of Aritao, Province of Nueva Vizcaya, a covert buy-bust operation was conducted.
The operation involved appellant Marilyn Miranda y Rama and her co-accused Imeldo Caoile, who were charged with allegedly selling 0.25 gram of methamphetamine hydrochloride (shabu) to a law enforcement officer acting as a poseur buyer.
The setup included police officers from the Aritao police station, with PO1 Henry Valenzuela designated to act as the buyer and given a P500.00 bill specifically for the operation.

Prior to targeting the appellant, the police team successfully executed a buy-bust operation against an individual named Reynaldo Mazo, from whom additional information about the local drug trade was obtained.
Based on Mazo’s revelations, the police planned a subsequent operation targeting the appellant at her residence.
Upon arriving at the appellant’s house, Mazo introduced PO1 Valenzuela to her, initiating the staged transaction.

During the operation, the appellant solicited the permission of her co-accused, Imeldo Caoile, and then proceeded to hand over four small, heat-sealed, transparent plastic sachets purportedly containing shabu.
In return, Reynaldo Mazo received a marked P500.00 bill, while PO1 Valenzuela observed the entire exchange.
Subsequent to the transaction, several police officers—including PO1 Rodelia Vergara and Police Chief Zaidee Daculog—entered the premises, conducted a frisk and a search, though no additional contraband was found.

The four seized plastic sachets were marked by PO1 Rodelia Vergara, in the presence of PO1 Valenzuela, who testified that these markings (aRCVa) denoted they were the same items handed over during the transaction.
The forensic chemist, Alfredo Quintero, confirmed through Chemistry Report No. D-003-2004 that the specimens positively tested for methamphetamine hydrochloride and further linked the markings to the accused.
The evidence was transferred to the provincial office of the PNP crime laboratory following proper procedures, including the preparation of a request for laboratory examination by PO1 Magdalena Alicum.

The prosecution’s case was predominantly supported by the testimony of PO1 Valenzuela, who provided a detailed account of the operation—from the initial meeting and planning to the transaction and subsequent marking of evidence.
The defense, however, presented the testimony of co-accused Caoile and that of the appellant, who maintained that no incriminating drug evidence was found during the search of her house and that she had no knowledge of the alleged shabu sale.
The appellant further argued that the record showing the marked money indicated a time discrepancy (the police blotter recorded the event at around 9:00 PM) and contended that the chain-of-custody for the plastic sachets was not definitively established.

The Regional Trial Court (RTC) of Nueva Vizcaya, Branch 37, in Criminal Case No. 1826, found appellant guilty beyond reasonable doubt of violating Section 5 of Republic Act No. 9165, sentencing her to life imprisonment plus a fine of P500,000.
On appeal, the Court of Appeals, in its Decision dated June 30, 2006, affirmed the RTC’s ruling, giving weight to the factual findings and credibility of the police testimonies, particularly that of PO1 Valenzuela.
The Office of the Solicitor General (OSG) defended the chain-of-custody and integrity of the evidence, and the appellate court noted that any procedural irregularities did not detract from the overall proof of the crime.
Appellant later sought a review by the Supreme Court, arguing that the prosecution failed to establish her guilt beyond reasonable doubt and raising issues related to evidentiary handling.

Whether the prosecution was able to prove beyond reasonable doubt that the appellant was involved in the illegal sale of a dangerous drug.

Whether the conduct of the buy-bust operation—specifically the use of a poseur buyer and the subsequent exchange—satisfactorily established the sale of shabu.
Whether the chain-of-custody of the seized plastic sachets was adequately maintained and proven.

Whether any procedural irregularities, such as the belated recording of the buy-bust money or deviations in the marking of the evidence, affected the reliability and admissibility of the evidence.
Whether the defense’s argument—that the buy-bust operation originally targeted Mazo and that the subsequent operation against the appellant was improperly conducted—renders the conviction untenable.