Case Summary (G.R. No. 223526)
Factual Background
Ariel was accused of selling three heat-sealed plastic sachets containing a total of 14.07 grams of Methamphetamine Hydrochloride (shabu) to a poseur buyer, Police Officer 2 Marites T. Villanueva, during a buy-bust operation facilitated by a confidential informant. The transaction allegedly took place at approximately 11:00 p.m. on November 26, 2005, in exchange for two marked five-hundred-peso bills. Upon conducting the operation, the police apprehended Ariel and recovered the marked money along with the illegal drugs shortly after the transaction was deemed consummated.
Prosecution's Version
The prosecution presented key testimonies from Villanueva and her partner, SPO2 Gerry Abalos, who described the buy-bust operation in detail. The prosecution followed proper protocols for surveillance, marking, and seizing the drugs, with Villanueva positively identifying Ariel during the sale and handover of the drugs. The drugs were subsequently turned over to the forensic laboratory, where they were confirmed to contain shabu.
Defense's Version
Ariel contended that he was falsely accused, asserting that he was at the Traveller's Inn purchasing food for his brother at the time of his arrest. He claimed the police officers used excessive force during his apprehension and maintained that his arrest was unlawful. Moreover, he asserted that the prosecution failed to present the informant, whose involvement would have clarified the events.
Ruling of the Regional Trial Court (RTC)
The RTC found Ariel guilty beyond reasonable doubt, sentencing him to life imprisonment and imposing a fine of one million pesos. The RTC ruled that the prosecution established a clear chain of custody and that the drugs presented in court matched those seized from Ariel during the buy-bust operation.
Ruling of the Court of Appeals (CA)
The CA affirmed the RTC's decision, concluding that the prosecution sufficiently proved Ariel's identity as the seller and substantiated the illegal sale of drugs. The Court emphasized that Villanueva's testimony was credible and that the absence of the informant did not nullify the prosecution's case, as Villanueva had firsthand knowledge of the transaction.
Legal Issues
Ariel raised three major issues on appeal: 1) whether the RTC erred in relying on the prosecution’s version despite alleged irregularities in the buy-bust operation; 2) whether the prosecution failed to establish the identity and integrity of the alleged confiscated drugs; and 3) whether due process was upheld in finding him guilty beyond reasonable doubt.
Supreme Court's Ruling
The Supreme Court dismissed Ariel's appeal, asserting that the prosecu
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Case Information
- Case Citation: 822 Phil. 423
- Court: Supreme Court of the Philippines, Third Division
- G.R. No.: 223526
- Decision Date: December 06, 2017
- Parties: People of the Philippines (Plaintiff-Appellee) vs. Ariel Calvelo y Consada (Accused-Appellant)
Background of the Case
- This case resolves the appeal of Ariel Calvelo y Consada from the decision of the Court of Appeals dated March 9, 2015.
- The Court of Appeals affirmed the judgment of the Regional Trial Court (RTC) dated April 26, 2013, which found Ariel guilty of violating Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
Facts of the Case
- Charge: Ariel was charged with the sale of methamphetamine hydrochloride (shabu) on November 26, 2005, at Traveller's Inn, Santa Cruz, Laguna.
- Details of the Incident:
- At approximately 11:00 PM, Ariel allegedly sold three heat-sealed plastic sachets of shabu (totaling 14.07 grams) to a poseur buyer, Police Officer 2 Marites T. Villanueva, for 60,000 pesos.
- Prior to the buy-bust operation, an informant alerted the Philippine Drug Enforcement Agency (PDEA) about the drug deal with Ariel.
- The team conducted surveillance and confirmed the location's suitability for the operation.
- Ariel was observed arriving on a tricycle and was introduced to Villanueva as the buyer.
- After an initial conversation, Ariel left but returned with the shabu, which he handed over to Villanueva after receiving the payment.
- Villanueva signaled for backup, leading to Ariel's arrest.
Prosecution's Version
- The prosecution presented testimonies from arresting officers and forensic chemists, establishing the identity of the drugs and the integrity of the buy-bust operation.
- Villanueva and arresting officer SPO2 Gerry Abalos provided detailed accounts of the transaction and arrest.
- Forensic chemist Police Senior Inspector Donna Villa P. Huelgas confirmed that the substances tested positive for methamphet