Title
People vs. Allen Udtojan Mantalaba
Case
G.R. No. 186227
Decision Date
Jul 20, 2011
The court upheld the conviction of Allen Mantalaba for violating drug laws, affirming the lower court's decision on guilt and modifying the penalty due to his minority status at the time of the crime.

Case Summary (G.R. No. 148325)

Relevant Facts

The Task Force Regional Anti-Crime Emergency Response (RACER) received information indicating that Mantalaba was selling shabu, a prohibited drug. A team was formed, and using marked money, a buy-bust operation was conducted. Mantalaba allegedly sold shabu to an undercover officer, leading to his arrest. Subsequent searches revealed more narcotics in his possession, resulting in the filing of two criminal cases against him for violation of Sections 5 and 11 of Republic Act No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002.

Trial Court Proceedings

Mantalaba pleaded not guilty to the charges. After a trial, the Regional Trial Court (RTC) found him guilty beyond reasonable doubt. He was sentenced to reclusion perpetua and fined P500,000 for the sale of shabu, and six years and one day to eight years for illegal possession, along with a fine of P300,000. The RTC emphasized the applicability of penalties in consideration of Mantalaba’s minority at the time of the crime.

Court of Appeals Decision

The Court of Appeals upheld the RTC's decision, affirming Mantalaba's conviction and sentences. It ruled that sufficient evidence had been presented to prove both the sale and possession of illegal drugs.

Appellant's Claims

In his appeal, Mantalaba argued that the prosecution failed to establish his guilt beyond a reasonable doubt, asserting that no actual sale occurred and challenging the integrity of the evidence chain. He maintained that he should be presumed innocent until proven guilty, placing the burden of proof on the prosecution.

Evaluation of Evidence

The Supreme Court examined testimonies and other evidence presented during the trial. It highlighted the importance of the undercover operation’s structured nature, affirming that all the elements of drug sale were met: the identity of the parties involved, the transaction of money for drugs, and the seizure of the substances. The testimonies from law enforcement officers supported the claim that Mantalaba was engaged in selling shabu, satisfying the requirements for proving drug-related offenses.

Chain of Custody Concerns

Mantalaba contended that the prosecution failed to establish the proper chain of custody for the confiscated drugs. The law, as established by Section 21 of RA 9165, demands that illicit drugs be inventoried and that the persons present during the inventory have to be consistently documented. The Supreme Court ruled that while some procedural aspects were not strictly followed, the integrity and evidentiary value of the evidence were maintained, thus not negating Mantalaba's conviction.

Age and Sentencing Considerations

At the time of the offense, Mantalaba was seventeen years old, a point of consideration in his sentencing. The ruling noted that he was no longer a minor when the RTC's decision was promulgated in 2005, which limited the applicability of suspension provisions that might have benefitted him as a juvenile offender. It held that despite the retroactive applicability of new laws concerning juvenile offenders, Mantalaba was not entitled to a suspension of his sentence as he had surpassed the age threshold for those provisions.

Final Judgment

The Supreme Court affirmed

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