G.R. No. 143951 - Mangaliag vs. Catubig-Pastoral

On March 13, 2003, in Pasig City, the buy-bust operation was initiated based on information from a civilian agent that a person nicknamed “Kirat” was selling illegal drugs.
The Pasig City Mayor’s Special Action Team, under the supervision of P/Insp. Rodrigo E. Villaruel of the Philippine National Police, organized a team composed of designated officers including SPO4 Manuel Buenconsejo (team leader), PO2 Arturo San Andres, PO1 Roland Panis, PO1 Janet Sabo, and PO3 Amilassan Salisa (poseur buyer).
The operation was provided with control number NOC-1303-03-04 by the Philippine Drug Enforcement Agency (PDEA).

The team, following a coordinated strategy involving an informant stationed at the scene, identified Willie Rivera as “Kirat” when he was seen near Villa Reyes St. in Barangay Bambang, Pasig City.
At approximately 12:55 PM, PO3 Salisa, using marked one hundred peso bills (P100), signaled the consummation of the transaction by having his cap removed.
Appellant Willie Rivera exchanged the two heat-sealed transparent sachets (each containing four centigrams of white crystalline substance) for the marked money.
Immediately after the transaction, the law enforcement team closed in, with PO3 Salisa apprehending Rivera by holding his arm, identifying himself as a police officer, and informing Rivera of his rights.

After the arrest, Rivera was taken first to Rizal Medical Center for a physical examination and subsequently to Pasig City Police Station.
A memorandum was issued by P/Insp. Villaruel at 3:00 PM on the same day requesting laboratory examination of the seized items.
By 3:55 PM, the sachets were delivered to the EPD-PNP Crime Laboratory where forensic chemist Police Inspector Lourdeliza M. Gural examined them.
The Chemistry Report (No. D-455-03-E) confirmed that the sachets contained methylamphetamine hydrochloride, a dangerous drug under Republic Act No. 9165.

The Information charged Willie Rivera with violating Section 5, Article II of R.A. 9165, specifically for willfully selling, delivering, and giving away dangerous drugs without authorization.
Testimonies, particularly from PO3 Salisa, played a crucial role in establishing the chain of events, culminating in evidence that linked Rivera to the transaction.
Rivera offered a defense version asserting that he was framed; he claimed that while walking to his mother’s house, he was accosted by police in the presence of several witnesses (described as “kibitzers”) and subsequently dragged into a van under duress.
Rivera further alleged that the officers attempted to extort him a substantial amount (initially P200,000, reduced to P20,000) before charging him with the offense.

The Regional Trial Court of Pasig City, Branch 154, convicted Rivera beyond reasonable doubt and imposed a sentence of life imprisonment along with a fine of P500,000.
Rivera’s case was subsequently reviewed by the Court of Appeals, which affirmed the conviction and the penalty.
On appeal to the Supreme Court, the main issues raised by Rivera related to the legality of his warrantless arrest and the evaluation of evidentiary testimony, including the adherence to procedural requirements such as Section 21 of R.A. 9165.

Whether the warrantless arrest of appellant Willie Rivera was lawful based on his actions during the buy-bust operation.
Whether Rivera’s subsequent conduct during arraignment and trial amounted to a waiver of his constitutional protection against illegal arrest.

Whether the trial court correctly credited the documentary and testimonial evidence, particularly that of PO3 Salisa, in convicting Rivera.
Whether the appellate courts erred in their deference to the trial court’s findings on witness credibility and overall circumstantial evidence.

Whether the non-compliance with certain procedural requirements under Section 21 of R.A. 9165 regarding the custody and disposition of confiscated evidence affected the integrity of the seized items.
Whether the justifications provided for any procedural lapses were sufficient to uphold the integrity and evidentiary value of the seized sachets.