G.R. No. 248264 - Tamboa y Laday vs. People

Petitioner Fredierose Tamboa y Laday was charged with the crime of Illegal Sale of Dangerous Drugs under Section 5, Article II of Republic Act No. 9165 (the “Comprehensive Dangerous Drugs Act of 2002”).
The charge arose from an Information filed before the Regional Trial Court (RTC) of Sanchez Mira, Cagayan, Branch 12, alleging that petitioner was involved in a buy-bust operation.

On the morning of June 10, 2015, police operatives acting on information from a confidential informant conducted a buy-bust operation in Claveria, Cagayan.
During the operation at an area fronting the Iglesia ni Cristo Church in Centro Uno, Claveria, a heat-sealed plastic sachet containing 0.137 gram of a white crystalline substance was recovered from petitioner’s possession.
The seized item was subsequently marked, inventoried, and photographed at the Claveria Police Station before being forwarded to the PNP Crime Laboratory at Regional Command 2, where tests confirmed the presence of methamphetamine hydrochloride (shabu).

In her defense, petitioner denied the charge and claimed that she was riding her motorcycle when a tricycle, carrying three men, collided with her vehicle.
She alleged that the men then arrested her without just cause and contrived evidence to falsely implicate her in selling illegal drugs.
Despite her defense, in a Judgment dated January 24, 2017, the RTC found petitioner guilty beyond reasonable doubt and sentenced her to life imprisonment and imposed a fine of P500,000.00, relying significantly on the testimony of the prosecution witnesses.

Dissatisfied with the conviction, petitioner appealed the RTC decision to the Court of Appeals (CA).
The CA dismissed her appeal in a Resolution dated February 15, 2018 for failure to file an appellant’s brief in time, as mandated by Section 8, Rule 124 of the Rules of Court, despite multiple motions for an extension.
Following the finality and entry of judgment on March 15, 2018, petitioner later sought to recall the entry of judgment and reinstate her appeal by filing a motion, explaining that the lapse was due to the alleged gross negligence of her previous counsel, Atty. Amelito A. Ruiz.

The CA denied petitioner’s motion to recall the entry of judgment and reinstate her appeal in a Resolution dated February 7, 2019.
A subsequent motion for reconsideration was also denied in a Resolution dated July 8, 2019, prompting the instant petition for review on certiorari before the Supreme Court.

Whether the Court of Appeals correctly dismissed petitioner’s appeal based solely on her failure to file an appellant’s brief within the prescribed period, without affording a full review of the merits of her case.