Case Summary (G.R. No. 179710)
Factual Background
On March 28, 2003, an Information was filed against Aldrin Berdadero for selling shabu, a dangerous drug, in violation of Section 5, Article II of RA 9165. Berdadero pleaded not guilty during his arraignment. Both the prosecution and the defense provided divergent narratives regarding the events leading to his arrest. The prosecution's account detailed a buy-bust operation led by police officers, supported by a confidential informant. The operation culminated in Berdadero allegedly exchanging shabu for marked money, leading to his arrest.
Prosecution’s Version
The prosecution argued that the police received information about Berdadero dealing drugs, leading to the preparation of a buy-bust operation. The informant, posing as a buyer, exchanged money for two sachets of shabu from Berdadero in an operation observed by law enforcement officers. After the transaction, Berdadero was apprehended, and the seized evidence was documented at the police station.
Defense’s Version
Conversely, Berdadero asserted that he was wrongfully accused and claimed he was a victim of a setup. He argued that he was unlawfully arrested by individuals who falsely identified themselves as locksmiths and denied selling drugs or being part of any buy-bust operation organized by the police.
Ruling of the Regional Trial Court
On October 10, 2005, the Regional Trial Court convicted Berdadero, concluding that the prosecution's evidence met the standards of moral certainty necessary for a conviction in a criminal case. He was sentenced to life imprisonment and ordered to pay a fine of P500,000, with the confiscated items ordered for proceedings as per law.
Ruling of the Court of Appeals
Berdadero appealed the trial court's decision to the Court of Appeals, which on July 3, 2007, affirmed the lower court's ruling. The appellate court expressed that the trial court did not err in its judgment.
Issues Raised on Appeal
On appeal, Berdadero raised two main errors: (1) the trial court allegedly disregarded his defense evidence, and (2) the prosecution did not sufficiently prove his guilt beyond a reasonable doubt. He argued that there was no buy-bust operation, questioned the compliance with Section 21 of RA 9165, and challenged the authority of the arresting officers.
Ruling on Appeal
The Supreme Court dismissed the appeal, affirming the findings of the trial and appellate courts. The court underscored the prosecution's need to demonstrate the legality of the sale of narcotics through sufficient evidence of the transaction's occurrence and the chain of custody for the seized drugs. Despite the defense's claims, the court determined the integrity and evidentiary value of the seized items were preserved and supported by credible witness testimony from the arresting officers.
Chain of Custody and Compliance with Section 21
The court noted that while there was a failure to strictly adhere to the inventory and photography requirements of Section 21 concerning seized substances, substantial compliance sufficed, provided the integrity and evidentiary value were maintained. The defense's arguments concerning procedural defects did not sw
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Factual Antecedents
- An Information was filed against Aldrin Berdadero y Armamento for the illegal sale of shabu, docketed as Criminal Case No. 12861, on March 28, 2003.
- The charges specified that on March 25, 2003, at Arrieta Subdivision, Batangas City, the appellant sold 0.04 grams of shabu without legal authorization.
- The appellant entered a plea of not guilty during arraignment.
The Version of the Prosecution
- The Batangas City Police, acting on an informant's tip about the appellant's drug dealings, organized a buy-bust operation.
- PO3 Danilo F. Balmes and PO2 Edwalberto M. Villas were involved in executing the operation, using an informant as a poseur-buyer.
- After the informant engaged with the appellant, he received two plastic sachets of shabu in exchange for marked money, which led to the appellant's arrest.
- The police informed the appellant of his rights and recorded the operation in the barangay hall's blotter.
- The seized drugs were marked and submitted for laboratory examination, confirming the presence of methamphetamine hydrochloride.
The Version of the Defense
- The appellant claimed he was a victim of a frame-up, asserting that he was arrested by two men posing as locksmiths.
- He stated that he never sold drugs and did not recognize the arresting officers as PO3 Balmes and PO2