Case Summary (G.R. No. 191260)
Factual Antecedents
On October 24, 2002, two separate informations were filed against Brita before the RTC of Pasig City, one for selling 0.19 grams of shabu in violation of Section 5, Article II of RA 9165 and the second for the illegal possession of 1.56 grams of shabu under Section 11, Article II of the same law. Following his arraignment on February 11, 2003, where he pleaded not guilty, Brita filed a petition for bail. During the bail hearing, the prosecution presented testimonies from the aforementioned police officers, which detailed the events leading to Brita's arrest during a buy-bust operation initiated on October 23, 2002.
Buy-Bust Operation
In this operation, Police Inspector Eduardo Paningbatan, upon receiving information regarding Brita’s drug-selling activities, led a buy-bust team. The police officers conducted a buy-bust where PO2 Tejero acted as the poseur buyer, handing Brita marked money in exchange for a plastic sachet containing a white crystalline substance, later identified as shabu. Following the transaction, the police apprehended Brita and recovered the buy-bust money and additional sachets of suspected shabu.
Trial Court Proceedings
Upon the conclusion of the prosecution's case, the RTC-Pasig, Branch 165, denied Brita's petition for bail but dismissed the charge concerning illegal possession of drugs due to insufficient evidence. The case was subsequently re-raffled to RTC-Taguig, Branch 70, which allowed Brita to post bail after reassessing the strength of the evidence. Despite Brita’s defense claiming a lack of credibility of the police testimonies and alleging a frame-up, on April 15, 2008, the RTC-Taguig found him guilty beyond reasonable doubt of illegal sale of dangerous drugs, imposing a sentence of life imprisonment and a fine of P500,000.00.
Court of Appeals Decision
Brita appealed to the Court of Appeals, which affirmed the RTC decision on November 18, 2009. The appellate court underscored that the testimonies of the law enforcement officers were credible and sufficient to establish Brita's guilt, despite Brita's claims regarding the presumption of innocence and the supposed weaknesses in the prosecution's case.
Appellant's Arguments
Brita raised several arguments on appeal, including the assertion that the presumption of regularity in the police's performance of duty cannot outweigh the presumption of innocence. He contested the credibility of the arresting officers due to alleged inconsistencies in their testimonies. He also contended that the grant of bail by the RTC indicated that the evidence against him was not strong enough, and he questioned the chain of custody of the seized drugs.
Evaluation of Arguments and Court's Rationale
The court found Brita's arguments lacking merit, affirming that the testimonies of the police officers were credible and consistent regarding the buy-bust operation. The court noted that minor discrepancies in their accounts did not undermine their overall credibility, as they did not detract from the central facts of the crime. It was emphasized that the presumption of regularity of official duties holds unless convincingly rebutted, which Brita failed to accomplish with his claims of frame-up.
Chain of Custody Concerns
Brita raised
...continue readingCase Syllabus (G.R. No. 191260)
Procedural Background
- The case is an appeal from the November 18, 2009 Decision of the Court of Appeals (CA) in CA-G.R. CR-H.C. No. 03561.
- The CA affirmed the April 15, 2008 Decision of the Regional Trial Court (RTC), Branch 70 in Taguig City.
- The RTC found Melchor D. Brita (alias "Boboy") guilty beyond reasonable doubt of violating Section 5, Article II of Republic Act (RA) No. 9165, resulting in a life imprisonment sentence and a fine of P500,000.00.
Factual Antecedents
- On October 24, 2002, two separate Informations were filed against the appellant for selling 0.19 grams of shabu and for illegal possession of 1.56 grams of shabu.
- The cases were raffled to RTC-Pasig, Branch 165, where the appellant pleaded not guilty after his arraignment on February 11, 2003.
- A buy-bust operation was conducted on October 23, 2002, after police received information about the appellant's illegal drug activities.
- Police conducted the operation, leading to the appellant's arrest, where marked money was recovered along with two plastic sachets containing suspected shabu.
Evidence Presented
- The prosecution presented testimonies from police officers involved in the buy-bust operation.
- PO2 Archibald Tejero acted as the poseur-buyer and testified about the transaction with the appellant.
- PO3 Edgar Orias corroborated the details of the arrest and the items recovered from the appellant.
- In defense, the appellant pr