G.R. No. 185848 - People vs. Sembrano y Castro

On 26 July 2004, during a buy-bust operation by the Station Anti-Illegal Drugs (SAID) of the Novaliches Police Station, Michael Sembrano y Castro (the accused-appellant) was arrested in broad daylight.
The operation followed a tip from a confidential informant regarding illicit drug trade operations in Gulod, Novaliches, Quezon City.
Two separate Informations were subsequently filed on 28 July 2004 by the Assistant City Prosecutor of Quezon City, charging Sembrano with:

The buy-bust team, led by Superintendent Ramon Perez, included police officers PO1 Jomar Manaol, SPO1 Cesar Futol, PO1 Kingly James Bagay, PO1 Neil John Dumlao, and PO1 Fernando Salonga.
The operation was executed as follows:

Around 3:00 p.m. on 26 July 2004, the confidential informant arrived at the SAID with information.
PO1 Manaol, designated as poseur-buyer, received two marked One Hundred Peso bills which he later used in the transaction.
The team moved to Ignacio Street corner Villareal Street in Gulod, arriving around 3:30 p.m.
At approximately 5:00 p.m., the informant introduced the poseur-buyer to the accused, facilitating the transaction.

PO1 Manaol executed a pre-arranged signal (scratching his head) indicating that the deal had been consummated.
The other team members promptly moved in to arrest Sembrano.
The drug evidence was collected:

One plastic sachet containing 0.12 gram (marked “JAM” by PO1 Manaol).
Two additional sachets recovered during a follow-up frisk (marked “KJB” by PO1 Bagay).

The seized items were processed and forwarded to the Philippine National Police Crime Laboratory, where a forensic examination confirmed the substances to be shabu.

Sembrano was arraigned on 19 April 2005 and pleaded not guilty.
The trial court, evaluating the testimonies of the police officers (PO1 Manaol and PO1 Bagay) and the documentary evidence (including the chain of custody and forensic reports), found Sembrano guilty beyond reasonable doubt for both charges.
The Regional Trial Court (RTC) delivered its Decision on 14 February 2007, imposing:

For illegal sale: Life imprisonment (originally with the penalty of death, later changed to life imprisonment due to Republic Act No. 9346) plus a fine of P500,000.00.
For illegal possession: An indeterminate penalty of imprisonment with a minimum of 12 years and one day to a maximum of 14 years plus a fine of P300,000.00.

The legality of his warrantless arrest, arguing that the evidence (i.e. the seized sachets of shabu) derived from an illegal arrest should be inadmissible under the “fruit of the poisonous tree” doctrine.
The credibility of the prosecution witnesses, claiming their testimonies were inconsistent and should have resulted in an acquittal.
His overall condemnation, asserting that the prosecution failed to prove his guilt beyond reasonable doubt.

The Court of Appeals, in its Decision on 18 June 2008, affirmed the trial court’s findings, though it reduced the penalty for the illegal possession case to a lesser term.
In his final appeal before the Supreme Court, the defense also raised that Sembrano was supposedly a police asset and claimed he was framed, presenting an Oath of Loyalty and Agent’s Agreement as evidence of this relationship. However, inconsistencies were noted during his testimony.

Whether the warrantless arrest during the buy-bust operation was lawful given the situation of catching the accused in flagrante delicto.
Whether the evidence (the seized sachets of shabu) should be declared inadmissible as fruit of an allegedly unlawful arrest.

Whether the testimonies of PO1 Manaol and PO1 Bagay, as provided during the trial and corroborated by each other, are sufficient to establish the accused’s involvement in the sale and possession of shabu.
Whether the defense’s challenge to the police officers’ credibility affects the overall finding of guilt.

Whether the evidence presented, including the forensic test results confirming the presence of methamphetamine hydrochloride, establishes the corpus delicti of the offenses charged.
Whether the chain of custody and marked items provide incontrovertible evidence linking the accused to the transaction and illegal possession of the drug.