Case Summary (G.R. No. 181836)
Background of the Case
Reyman Endaya y Laig was charged with two offenses: illegal sale of methamphetamine hydrochloride (shabu) and illegal possession of dangerous drugs under Republic Act No. 9165. The alleged offenses stemmed from a buy-bust operation executed by police operatives based on a prior surveillance that indicated Endaya was involved in illegal drug activities.
Prosecution's Version
On November 11, 2002, police officers conducted surveillance on Endaya. On November 20, using a civilian asset to pose as a buyer with marked currency, they executed a buy-bust operation at a local beer garden. The police witnessed the exchange of marked money for a sachet of shabu, leading to Endaya's arrest. Following the arrest, the police conducted a body search yielding an additional eight sachets of shabu. The integrity of the evidence was meticulously documented, including the presence of witnesses during the inventory of seized items.
Defense's Version
Endaya denied the allegations, claiming he was with his family at home during the time of the alleged crime. He suggested that the police collected evidence through coercion and aggression, including physical threats and demands for confession. He asserted that the procedures followed during his arrest and subsequent actions at the police station did not respect his constitutional rights, particularly regarding the signing of the Receipt for Property Seized without legal counsel.
Ruling of the Trial Court
The Regional Trial Court found Endaya guilty, asserting that the prosecution successfully proved all necessary elements of both charges beyond a reasonable doubt. The court meted out sentences in accordance with RA 9165, including life imprisonment for the illegal sale and a 12 to 20-year prison term for illegal possession, as well as substantial fines.
Ruling of the Court of Appeals
The Court of Appeals upheld the decision of the trial court, stating that the prosecution had established beyond a reasonable doubt that the crime was committed. The appellate court dismissed claims of inconsistencies in witness testimonies as minor details not affecting the overall credibility. It emphasized that law enforcement's conduct was regular and that Endaya failed to demonstrate any bad faith or ill motive from the police.
Key Issues Raised by the Appellant
- Claim that insufficient evidence was presented to prove guilt beyond reasonable doubt.
- Argument that admitting the Receipt for Property Seized violated constitutional rights due to the absence of legal counsel during the signing.
- Assertion that the sachets of shabu were inadmissible as they were the "fruits of a poisonous tree" resulting from an illegal search and seizure.
Court's Anal
Case Syllabus (G.R. No. 181836)
Case Citation
- G.R. No. 205741
- Decided on July 23, 2014
- Jurisprudence: 739 PHIL 611
Background of the Case
- This case revolves around the appeal of Reyman Endaya y Laig (appellant) against the Decision of the Court of Appeals (CA) affirming his conviction for illegal sale and illegal possession of methamphetamine hydrochloride, commonly known as shabu.
- The charges stem from two separate informations filed against him under Republic Act (R.A.) No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002.
Antecedents
- Criminal Case No. 0098-2003: Appellant was charged with illegal possession of eight heat-sealed plastic sachets of shabu, totaling 0.32 grams.
- Criminal Case No. 0099-2003: Appellant was charged with the illegal sale of one heat-sealed sachet of shabu weighing 0.04 grams.
- Both incidents occurred on November 20, 2002, at Barangay 2-A, Mataasnakahoy, Batangas.
Prosecution's Version of Events
- The police conducted surveillance after receiving reports about appellant's involvement in illegal drug activities.
- On November 20, 2002, a buy-bust operation was executed where a civilian asset posed as a buyer, using marked money to purchase shabu from the appellant.
- The police operatives witnessed the transaction, arrested the appellant immediately after the sale, and conducted searches leading to the discovery of additional sachets of shabu in his possession.
- An inventory of the seized items was made in the presence of witnesses, and the