Case Summary (G.R. No. 217428)
Background of the Case
The case stems from the appeal of SPO1 Alexander Estabillo y Palara following his conviction by the Regional Trial Court for violating Sections 5 and 11 of Republic Act No. 9165. The evidence against the accused involved two separate Information charges linked to a buy-bust operation conducted in Pasig City on June 14, 2010. The appellant was accused of illegal sale and possession of cocaine.
Prosecution's Version
The prosecution established the context of the operation, wherein a confidential informant alerted Police Superintendent Acierto of suspected drug activities by a police officer named "Alex." A buy-bust operation was coordinated, leading to a meeting where officer SPO2 Taldo acted as the poseur buyer. The prosecution detailed how the transaction unfolded, including appellant’s delivery of cocaine in exchange for cash—a transaction made within the view of law enforcement. Subsequent searches yielded additional cocaine from the appellant's vehicle, corroborating the illegal nature of his activities.
Defense's Position
The defense presented a differing narrative, claiming that the accused was a victim of a violent abduction rather than a perpetrator of a drug sale. Appellant claimed he was followed and forcibly taken by armed individuals. He denied ownership of the drugs found during the police operation, arguing inadequate evidence to establish his guilt and pointing to procedural lapses during the buy-bust operation.
Ruling of the Trial Court
The Regional Trial Court upheld the prosecution's evidence, finding the appellant guilty of both charges. The court clarified that the essential elements of illegal sale and possession were proven, particularly the unbroken chain of custody for the seized drugs. It imposed life imprisonment and a fine of ten million pesos for each violation of the law.
Arguments on Appeal
On appeal, the appellant challenged the trial court's findings, asserting that:
- His arrest was unlawful, lacking probable cause.
- There was no direct evidence connecting him to the drugs since officers lacked knowledge of the package contents.
- The absence of a Department of Justice (DOJ) representative during inventory procedures compromised the integrity of the operation.
- There were discrepancies in the chain of custody concerning the handling of seized drugs.
The Court of Appeals' Conclusion
The Court of Appeals affirmed the trial court's decision, determining that the appellant was rightly arrested in the act of selling drugs—the consensual nature of his interaction with the poseur buyer establishe
...continue readingCase Syllabus (G.R. No. 217428)
The Case
- This appeal concerns the decisions of the Court of Appeals in CA-G.R. CR-HC No. 08244, which affirmed the conviction of SPO1 Alexander Estabillo y Palara for violating Sections 5 and 11 of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
- The appellate decision dated April 26, 2019, confirmed the trial court's verdict, and the subsequent resolution dated October 9, 2019, denied a motion for reconsideration.
Antecedents
- Appellant was charged under two separate Informations dated July 13, 2010:
- Criminal Case No. 17172-D-PSG: Illegal possession of two bricks of cocaine (approximately 1078.89 grams and 1041.57 grams) on June 14, 2010.
- Criminal Case No. 17173-D-PSG: Illegal sale of two bricks of cocaine (approximately 1046.22 grams and 1065.75 grams) to SPO2 Leonardo G. Taldo during a buy-bust operation on the same date.
- The appellant pleaded not guilty to both charges at arraignment, initiating a trial.
Version of the Prosecution
- The prosecution's narrative began with a report from a confidential informant regarding the drug activities of a police officer named "Alex," later identified as the appellant.
- Following a successful test buy on June 14, 2010, a buy-bust operation was organized which culminated in the arrest of the appellant.
- Testimonies from various police officers and a forensic chemist established the details of the buy-bust operation:
- A meeting occurred at A Venue in Makati City, where SPO2 Taldo, as the poseur buyer, arranged to purchase cocaine from the appellant.
- Appellant was arrested shortly after he exchanged bricks of suspected cocaine for boodle money dusted w