Case Summary (G.R. No. 231839)
Charges and Legal Framework
Michael Ryan Arellano y Navarro faced charges under three criminal cases:
- Criminal Case No. 15491: Illegal possession of methamphetamine hydrochloride (shabu).
- Criminal Case No. 15492: Illegal sale of shabu.
- Criminal Case No. 15493: Illegal possession of paraphernalia.
All charges were based on violations of Sections 5, 11, and 12 of Republic Act No. 9165. The incidents took place on April 18, 2013, in Laoag City.
Procedural Background
Upon his arrest, the accused pleaded not guilty to all charges. The prosecution's case commenced with a buy-bust operation, where a confidential informant tipped off authorities about Arellano’s drug activities. The police conducted the operation in coordination with the informant, resulting in the recovery of shabu and paraphernalia from the accused's possession during the operation at Farmside Hotel.
Evidence Presentation
During the trial, the prosecution presented testimonial evidence from the poseur-buyer and other law enforcement officers involved in the buy-bust operation. Forensic analysis confirmed the identity of the seized substances as illegal drugs through laboratory examination. Conversely, the defense rested on Arellano's testimony, claiming he was falsely accused, insisting on a supposed frame-up by the police.
RTC's Judgment
On September 11, 2015, the RTC found Arellano guilty on all counts and imposed several penalties, including life imprisonment for illegal sale and long prison terms for possession charges, along with substantial fines.
Appeal and Court of Appeals Findings
Arellano appealed, disputing the integrity of the prosecution's case, particularly the chain of custody and the officers' credibility. However, the CA upheld the RTC's conviction, recognizing that the prosecution sufficiently established its case beyond reasonable doubt.
Supreme Court's Review
Upon review, the Supreme Court adhered to the principle of presumption of innocence, emphasizing that any doubt regarding the accused's guilt must favor him. The Court noted inconsistencies in the testimonies of law enforcement witnesses, particularly concerning the presenc
...continue readingCase Syllabus (G.R. No. 231839)
Case Overview
- This case concerns the appeal of accused-appellant Michael Ryan Arellano y Navarro against his conviction for violations of the Comprehensive Dangerous Drugs Act of 2002, specifically Sections 5, 11, and 12 of Republic Act No. 9165.
- The conviction was affirmed by the Court of Appeals (CA) following an earlier ruling by the Regional Trial Court (RTC) of Laoag City, which found him guilty beyond reasonable doubt of illegal possession and sale of drugs, as well as illegal possession of drug paraphernalia.
Antecedents of the Case
Criminal Charges:
- Criminal Case No. 15491: Accused possessed three heat-sealed plastic sachets containing methamphetamine hydrochloride (shabu) weighing 0.2143 grams without any license or authority.
- Criminal Case No. 15492: Accused sold one plastic sachet of shabu weighing 0.1780 grams to a poseur buyer without a license.
- Criminal Case No. 15493: Accused possessed two folded aluminum foils, categorized as drug paraphernalia, without any license.
Incident Background:
- On April 18, 2013, a confidential informant reported the accused's involvement in illegal drug activities to the Provincial Anti-Illegal Drugs Special Operations Task Group (PAIDSOTG).
- A buy-bust operation was conducted where a police officer acted as a poseur buyer and arranged a meeting with the accused.
The Buy-Bust Operation
- The operation commenced at approximately 9:30 a.m. with arrangements made for the sale of shabu worth P1,000.
- The accused directed the informant to a new location, Farmside Hotel, where t