Case Summary (G.R. No. 241950)
Facts of the Case
On February 27, 2014, an Information was filed against Malabanan, Quita, and another individual, Roque Heredia, alleging that they unlawfully sold methamphetamine hydrochloride, commonly known as "shabu." The accusation occurred in Brgy. Pansol, Calamba City, where the police conducted a buy-bust operation following a tip-off from a confidential informant. Police Officer 1 (PO1) Alvin Santos acted as the poseur-buyer and was provided marked money for the operation.
During the buy-bust, PO1 Santos successfully completed the transaction, handing money to Malabanan and receiving a plastic sachet from Heredia. Upon the execution of a pre-arranged signal, the police arrested Malabanan, Quita, and Heredia. The police conducted a physical inventory of the seized evidence, which was later confirmed to contain illegal drugs through laboratory examination.
Prosecution's Evidence
The prosecution's evidence consisted of the testimonies of PO1 Santos and other officers involved in the operation, along with the physical evidence, which included the seized drugs. The prosecution established the elements of illegal sale by demonstrating that the accused were involved in the transaction and that the drugs recovered were indeed shabu.
Defense Arguments
In their defense, both accused-appellants claimed they were not at the buy-bust site at the time of the arrest. Quita argued that he was assisting someone with a task in another location, while Malabanan contended he was on his way to go fishing. Both accused argued that they were victims of police abuse, asserting they were seized without due process and coerced into a narrative that incriminated them.
RTC Ruling
In its November 4, 2016 Judgment, the RTC convicted both Malabanan and Quita, citing sufficient evidence from the prosecution to support a conviction for the sale of illegal drugs. The court found PO1 Santos's identification of the defendants credible and dismissed their defense based on denial, emphasizing that the prosecution's evidence established an unbroken chain of custody regarding the seized items. As a result, both accused were sentenced to life imprisonment and a monetary fine.
CA Ruling
The CA affirmed the RTC's decision on March 26, 2018. It agreed that the elements of illegal sale were established and maintained that the buy-bust operation adhered to legal requirements. The CA dismissed the appellants’ claims regarding procedural lapses, asserting that such deficiencies did not compromise the integrity of the evidence, as the prosecution had sufficiently preserved the chain of custody.
Supreme Court's Ruling
Upon appeal to the Supreme Court, the pivotal issue was whether the accused-appellants were guilty beyond reasonable doubt of the drug sale charge. The Supreme Court emphasized the necessity of proving the identity and integrity of the seized drugs to uphold a conviction in drug-relat
...continue readingCase Syllabus (G.R. No. 241950)
Case Background
- This case arises from an appeal against the March 26, 2018 Decision of the Court of Appeals (CA) in CA-G.R. CR-HC No. 08851.
- The CA affirmed the November 4, 2016 Judgment of the Regional Trial Court (RTC) in Criminal Case No. 22175-2014-C, which found accused-appellants Arcadio Malabanan y Peralta (Malabanan) and Norman Quita y Quibido (Quita) guilty beyond reasonable doubt of violating Section 5, Article II of Republic Act (R.A.) No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002.
The Facts of the Case
- On February 27, 2014, an Information was filed charging Malabanan and Quita, along with a co-accused named Roque Heredia, with selling Methamphetamine Hydrochloride (shabu) without lawful authority.
- The incident occurred at approximately 12:30 a.m. on February 25, 2014, in Brgy. Pansol, Calamba City.
- During their arraignment on May 8, 2014, all accused pleaded "Not Guilty."
- Evidence presented by the prosecution detailed a buy-bust operation initiated following a tip from a confidential informant.
Evidence for the Prosecution
- The Calamba City Police received information about drug sales being conducted by the accused at Heredia's residence.
- A buy-bust operation was organized, with Police Officer 1 Alvin Santos designated as the poseur-buyer.
- Santos was provided with marked money amounting to P1,000.00 for the purchase of shabu.
- Upon entering Heredia's home, Santos was introduced to the accused and negotiated the purchase, eventually handing the marked money to Malabanan, who passed it to Heredia in exchange for a plastic sachet containing shabu.
- Following the transaction, Santos signaled to other officers for the arrest, leading to Malabanan, Quita, and Heredia's