Case Summary (G.R. No. 191396)
Offenses Charged
Two separate Informations were filed against Aguilar in the Regional Trial Court (RTC) of Pasay City, charging her with:
- Possession of 0.31 grams of Methamphetamine Hydrochloride (shabu) (Criminal Case No. 04-2962-CFM).
- Sale and delivery of 0.45 grams of Methamphetamine Hydrochloride (shabu) (Criminal Case No. 04-2963-CFM).
Procedural Background
Aguilar, upon arraignment, pleaded not guilty to both charges. During the pre-trial, her defense counsel admitted certain documents and Aguilar's identity as the person arrested by police. The RTC considered the validity of Aguilar's arrest and the legality of the search conducted without a warrant as part of the issues for resolution.
Prosecution Evidence
The prosecution's case was primarily supported by the testimony of Police Officer 2 (PO2) Roel Medrano, who acted as the poseur-buyer during a buy-bust operation against Aguilar. Medrano detailed the operation, which included receiving information about drug dealing, planning the buy-bust, and the actual transaction with Aguilar. After the purchase, police arrested Aguilar and seized two sachets of shabu. A forensic chemist confirmed that both samples contained Methamphetamine Hydrochloride.
Defense Claims
Aguilar denied the charges, claiming she was extrajudicially apprehended by the police without explanation and contending that no buy-bust operation against her took place. She alleged police demanded a bribe for her release, claiming the drugs were planted. Her niece, Gerolyn A. Lazaro, testified in her defense but lacked specific details about the events.
RTC Ruling
The RTC found that the prosecution established Aguilar's guilt beyond reasonable doubt and convicted her:
- For Criminal Case No. 04-2962-CFM, she was sentenced to 12 years and 1 day to 14 years and 4 months, plus a fine of P300,000.
- For Criminal Case No. 04-2963-CFM, she received a sentence of life imprisonment and a fine of P500,000. The RTC ruled that Aguilar's defenses of denial and frame-up lacked credibility compared to the prosecution's evidence.
Court of Appeals Decision
Aguilar's appeal was filed, citing errors in the RTC's findings. The Court of Appeals upheld the lower court's decision, confirming that the prosecution proved Aguilar's guilt beyond reasonable doubt.
Issues Raised on Appeal
Aguilar contended that:
- The RTC erred in finding her guilty as her guilt was not established beyond reasonable doubt.
- The RTC failed to give weight to her defense of denial and frame-up.
Supreme Court's Ruling
The Supreme Court reviewed the records and found no reason to overturn the decisions of the lower courts. The elements of both illegal sale and possession of dangerous drugs were proven. The Court acknowledged that while the police did not follow exact protocols concerning the custody of the seized drugs, the chain of custody was sufficiently maintained as the integrity and evidentiary value of the evidence were preserved.
Defense of Denial and Frame-up
Aguilar's claims of denial and frame-up were not believed, as her accusations against the police lacked convincing evidence. Lazaro's testimony did not provide sufficient su
...continue readingCase Syllabus (G.R. No. 191396)
Case Information
- Court: Supreme Court of the Philippines
- Case Number: G.R. No. 191396
- Decision Date: April 17, 2013
- Division: First Division
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellant: Marilyn Aguilar y Manzanillo
Procedural History
- The case is a review of the November 26, 2009 Decision of the Court of Appeals, which affirmed an earlier ruling by the Regional Trial Court (RTC).
- The RTC had found Aguilar guilty of violating Sections 5 and 11, Article II of Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002.
- Two separate Informations were filed on December 1, 2004, in the Pasay City RTC, Branch 116, leading to Aguilar's arraignment on January 10, 2005, where she pleaded not guilty.
Facts of the Case
- Aguilar was charged in Criminal Case No. 04-2962-CFM for possession of 0.31 grams of Methamphetamine Hydrochloride (shabu) and in Criminal Case No. 04-2963-CFM for selling 0.45 grams of shabu.
- During the pre-trial conference, Aguilar's counsel admitted the authenticity of several pieces of evidence, including the drug test request and the identity of Aguilar as the arrested individual.
- The prosecution's case involved testimonies from Police Officer 2 (PO2) Roel Medrano, who acted as the poseur-buyer, and Police Inspector Angel Timario, a forensic chemist.
Prosecution's Evidence
- A week prior to Aguilar's arrest, PO2 Medrano received information about drug dealing in Pasay City, leading to a surveillance operation.
- On November 30, 2004, an entrapment operation was conducted where PO2 Medrano, acting as a buyer, exchanged marked money for shabu with a woman known as Baby Mata.
- After the transaction, police apprehended Baby Mata and confiscated both the buy-bust money and additional shabu found in her possession.
- The substances w