Case Summary (G.R. No. 246179)
Summary of Charges
Jesusa Figueroa faced two charges related to illegal drug possession and intent to sell narcotics under Republic Act No. 9165. In Criminal Case No. 04-2432, she was accused of possessing 9.42 grams of Methylamphetamine Hydrochloride (shabu) without lawful authority. In Criminal Case No. 04-2433, she was accused of the attempted sale of 4.60 grams of the same substance. She pleaded not guilty in both cases.
Seeking Justice: Trial Proceedings
The Regional Trial Court (RTC) in Makati City presided over the trial wherein testimony was presented by both the prosecution and defense. The prosecution, supported by surveillance and operational details from police officers, recounted how an informant facilitated a buy-bust operation targeting Figueroa, culminating in her arrest on July 2, 2004, when police officers attempted to execute the planned purchase of illegal drugs.
Prosecution Evidence and Events
The prosecution's case was built on meticulous police operations. An informant indicated Figueroa's drug-pushing status, initiating surveillance. On July 2, arrangements were made for a staged drug purchase involving marked bills. Figueroa arrived with the drugs but fled when sensing police presence. Substantial evidence followed her arrest, including recovered shabu from her vehicle and the conducted field tests, which confirmed the substance's identity.
Defense Arguments
Figueroa's defense centered on denying both the drug transaction and ownership of the recovered substances. She contended that she was traveling to a relative's home when she was confronted by police, suggesting that any seized evidence was planted or unrelated to her. Furthermore, she argued procedural irregularities concerning the lack of coordination between the police and the Philippine Drug Enforcement Agency (PDEA) during the buy-bust operation.
RTC Decision
The RTC acquitted Figueroa of the possession charge but convicted her of the attempted sale of shabu under Criminal Case No. 04-2433, sentencing her to life imprisonment and a fine of P500,000. The court found credible the prosecution's evidence, ruling that the attempted sale was demonstrably established and not undermined by the defense's claims.
Appeal to the Court of Appeals
Figueroa appealed, arguing the RTC's findings were erroneous, particularly concerning the alleged lack of coordination with the PDEA and the assertion that the prosecution did not demonstrate a prior agreement between her and the officers involved. She also cited inconsistencies in witness testimonies as undermining their credibility.
Court of Appeals Findings
The Court of Appeals upheld the RTC’s decision, asserting that the operation's legality was not invalidated by alleged procedural lapses in coordination with the PDEA. The Court further determined
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Case Overview
- The case involves an appeal by Jesusa Figueroa y Coronado (accused-appellant) against the Decision of the Court of Appeals affirming her conviction for the violation of Section 26, Article II of Republic Act No. 9165 (the Comprehensive Dangerous Drugs Act of 2002).
- The appeal is rooted in Criminal Case No. 04-2433 concerning the attempted sale of dangerous drugs (Methylamphetamine Hydrochloride, commonly known as shabu).
Facts of the Case
- On or about July 2, 2004, in Makati City, the accused-appellant was charged with possessing and attempting to sell 4.60 grams of shabu without a license or prescription.
- The prosecution's case stemmed from a police operation initiated after an informant informed P/Supt. Nelson T. Yabut of a drug-pushing activity involving the accused-appellant.
Prosecution's Version
- Initial Surveillance: On June 20, 2004, the informant reported the accused's activities leading to a discreet surveillance operation.
- Buy-Bust Operation Setup: On July 2, 2004, the informant communicated with the accused, leading to an agreement to buy shabu worth P10,000.
- Execution of Buy-Bust: The police, posing as buyers, approached the accused at a designated location. Upon sensing police presence, the accused fled, leading to a chase.
- Evidence Collection: After the chase, the police recovered shabu from a plastic bag thrown by a passenger of the accused's vehicle and additional sachets from the vehicle itself