Case Digest (G.R. No. 185284)
Facts:
- Jason Sy was charged with the illegal sale of methamphetamine hydrochloride (shabu) under Section 15, Article III of Republic Act No. 6425, as amended.
- The incident occurred on December 3, 2000, in San Fernando, Pampanga.
- The prosecution's case stemmed from a buy-bust operation by the Special Action Team of the Criminal Investigation and Detection Group (CIDG).
- Police received information about a drug deal involving Sy on the night of December 2, 2000.
- At approximately 2:00 AM on December 3, police officers conducted the operation at a Chowking restaurant.
- PO2 Christian Trambulo acted as a poseur-buyer, negotiating the purchase of one kilogram of shabu for Php 5,000.
- After the transaction, police arrested Sy and recovered marked money and a carton box containing 987.32265 grams of shabu.
- The Regional Trial Court (RTC) found Sy guilty and sentenced him to reclusion perpetua based on the credibility of witnesses and physical evidence.
- Sy appealed, claiming insufficient evidence and alleging he was a victim of "hulidap" (abduction by police).
Issue:
- (Unlock)
Ruling:
- The Supreme Court affirmed the Court of Appeals' decision, which upheld the RTC's conviction of Jason Sy for the illegal sale of shabu.
- The Court found that the prosecution established Sy's guilt beyond reasonable doubt.
- The defense's claims of "hulidap" and irregularities in the buy-bust operation did not negate the prosecution's evidence.
Ratio:
- The Supreme Court highlighted that the prosecution must prove the elements of illegal drug sale, including the actual sale and the seller's knowledge of the drug's nature.
- Testimonies from police officers were credible and consistent, detailing the negotiation, transaction, and arrest of Sy.
- The presumption of innocence is fundamental but does not relieve the prosecution of its burden to prove guilt beyond reasonable doubt.
- The Court addressed the "hulidap" claim, stating that potential police misconduct does not automatically invalidate the prosecution's case if evidence supports conviction.
- The absence of the confidential informant was deemed non-fatal, as arresting officers' testimonies sufficed to establish the sale.
- Procedural irregularities, such as missing police blotter entries or lack of fluorescent powder on buy-bust money, do not necessarily undermine the operation's validity.
- The integrity of the chain of custody for the seized drugs was maintained, and physical evidence corroborated prosecution witnesses' testimonies.
- The Court affirmed the penalties, including reclusion perpetua and a fine of Php 500,000, due to the quantity of shabu exceeding the threshold for severe penalties under the law.
Case Digest (G.R. No. 185284)
Facts:
The case involves Jason Sy, who was charged with the illegal sale of methamphetamine hydrochloride (shabu) in violation of Section 15, Article III of Republic Act No. 6425, as amended. The events leading to the charge occurred on December 3, 2000, in San Fernando, Pampanga. The prosecution's case was built around a buy-bust operation conducted by the police, specifically the Special Action Team of ...