Case Summary (G.R. No. 191064)
Background and Charges
The case originates from a buy-bust operation conducted on July 5, 2002, in Pasig City, where the accused were apprehended for allegedly violating Sections 5 and 11 of Article II of Republic Act No. 9165, known as the "Comprehensive Dangerous Drugs Act of 2002." The accused were found selling and possessing illegal drugs, specifically methamphetamine hydrochloride (shabu) and marijuana.
Summary of Prosecution’s Evidence
During the buy-bust operation, the police received a confidential tip about the illegal drug activities of the accused. The operatives formed a team and, after confirming the informant's report, proceeded to the target location. The operation unfolded with the designated poseur-buyer obtaining drugs from the accused in exchange for marked money. The operation concluded with the arrest of the accused after the successful transaction.
Summary of Defense Evidence
The accused asserted they were subjected to an illegal arrest without proper warrants. They claimed that upon being confronted by the police, they were simply sleeping when the officers barged in and claimed a search was conducted illegally without finding anything incriminating. The defense further described alleged attempts by the police to extort money in exchange for their release.
Ruling of the Regional Trial Court
The Regional Trial Court found both accused guilty beyond reasonable doubt, sentencing them to life imprisonment and fines for violation of Section 5, and for Rolando, an additional sentence for violation of Section 11. The RTC held that all elements of the offenses were established through the buy-bust operation and the testimonies of law enforcement were credible.
Ruling of the Court of Appeals
On appeal, the Court of Appeals affirmed the RTC’s ruling. It emphasized that the prosecution met the "objective test" necessary in buy-bust operations, which includes detailing the transaction from initial contact to the delivery of the illegal items. The CA also found the defense's claims of police misconduct insufficient and upheld the presumption of regularity regarding the actions of the law enforcement officers.
Key Legal Issues
- Legality of Arrest and Search: The court confirmed that the buy-bust operation was a lawful m
Case Syllabus (G.R. No. 191064)
Case Overview
- This case is an appeal concerning the convictions of Rolando Araneta y Abella (a.k.a. "Botong") and Marilou Santos y Tantay (a.k.a. "Malou") for drug-related offenses under Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002.
- The appeal arises from a decision by the Court of Appeals (CA) affirming the ruling of the Regional Trial Court (RTC) which found the accused guilty beyond reasonable doubt for violating Sections 5 and 11 of Article II of the said law.
Background of the Case
- Criminal informations were initially filed against the accused under the Dangerous Drugs Act of 1972 but were amended following the enactment of R.A. No. 9165.
- The prosecution's allegations stemmed from a buy-bust operation conducted on July 5, 2002, in Pasig City, where the accused were caught selling and possessing dangerous drugs.
Prosecution’s Evidence
- An informant reported the illegal drug activities of the accused to the Station Drug Enforcement Unit (SDEU) of the Pasig City Police.
- A buy-bust operation was organized, with PO2 Danilo Damasco acting as the poseur buyer.
- The operation resulted in the purchase of a sachet of methamphetamine hydrochloride from the accused, with the marked money being exchanged during the transaction.
- Upon arrest, additional plastic sachets containing drugs were recovered from the accused.
Defense Evidence
- The accused testified that they were asleep during the police operation and were awakened by loud noises.
- Th