Case Summary (G.R. No. 182790)
Legal Proceedings
Following the filing of an Information against the appellant, he pleaded not guilty during arraignment. The prosecution's case relied on testimonies from police officers involved in the operation, while the defense presented testimonies from the appellant and his family. The prosecution established that the apprehension took place after a planned buy-bust operation, with police assets reporting illegal drug activities involving the appellant.
Prosecution's Case
The prosecution outlined that two police assets reported the appellant's drug dealings, prompting an entrapment team led by SPO4 Celso Jeresano to intervene. Evidence was presented detailing how the poseur-buyer, PO2 Paul Acosta, engaged with the appellant, resulting in the alleged sale of a plastic sachet of shabu, a form of methamphetamine. This purported transaction was supported by further evidence of the marked buy-bust money recovered from the appellant.
Defense's Argument
In contrast, the defense contended that no drug sale occurred. The appellant described an intruding group of armed men, who forcefully entered their home and searched for drugs. The defense established a narrative suggesting that the police acted without a warrant and resorted to coercion, thus framing the appellant and conducting an unlawful search.
Trial Court's Decision
The Regional Trial Court of Quezon City subsequently found the appellant guilty, sentenced him to life imprisonment, and imposed a fine, asserting that the prosecution sufficiently proved the necessary elements of the crime charged.
Appellate Review
Upon appeal, the Court of Appeals affirmed the trial court's ruling, highlighting that the constitutional presumption of innocence had been overridden by the prosecution's evidence. The appellant argued that the trial court ignored significant elements of reasonable doubt and procedural violations regarding search and seizure.
Supreme Court Findings
The Supreme Court convened to evaluate the merits of the appeal and found the need for a more thorough examination of the evidence presented at trial. The decision underscored that the prosecution had failed to meet the burden of proof required, noting that the testimonies from the police lacked corroborative details, particularly regarding the chain of custody of the seized drugs. Additionally, no rebuttal evidence was provided by the prosecution to counter the defense's claims of a frame-up.
Circumstantial Evidence and Doubt
The Court emphas
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Case Overview
- This case involves an appeal by Cesar Cantalejo y Manlangit against his conviction for violating Section 5 of Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002.
- The Regional Trial Court found him guilty, sentencing him to life imprisonment and a fine of P500,000.00.
- The appeal was heard by the Court of Appeals, which upheld the trial court's decision.
Factual Background
- On January 20, 2004, police assets reported illegal drug activities linked to a person named "Cesar" in Quezon City.
- An entrapment operation was organized by police, led by SPO4 Celso Jeresano, with PO2 Paul Acosta designated as the poseur-buyer.
- PO2 Acosta was given P500.00 marked as buy-bust money.
- The operation commenced around 1:00 AM, leading to a confrontation at Cesar's residence where a buy-bust transaction allegedly took place.
- PO2 Acosta exchanged the marked money for a plastic sachet, purportedly containing shabu, which led to Cesar's arrest.
Defense's Argument
- The defense argued that Cesar and his family were asleep at home when police officers forcibly entered their house.
- They alleged that the police officers did not have a warrant and conducted an unreasonable search.
- Testimony from Cesar's wife supported a narrative of frame-up, as the police officers purportedly did not even know Cesar’s identity when they entered the home.
Trial Court Proceedings
- The trial court evaluated the testimonies from both the prosecution and defense.
- The prosecution relied heav