Case Summary (G.R. No. 187496)
Case Background and Charges
- Malik Manalao was charged with violating Sections 5 and 11, Article II of Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002.
- Two separate Informations were filed against him, detailing the sale and possession of Methamphetamine Hydrochloride (shabu) on June 15, 2004, in Tubod, Lanao del Norte.
- Manalao pleaded not guilty during his arraignment on August 9, 2004, and the cases were consolidated for trial.
Prosecution's Evidence
- The prosecution presented witnesses, including Senior Police Inspector Mary Leocy Jabonillo Mag-abo, a forensic chemist, and Police Officer 1 Michael Solarta, who participated in the buy-bust operation.
- The operation was initiated based on reports of Manalao's drug activities, leading to a planned entrapment on June 15, 2004.
- During the operation, Manalao was observed selling shabu to a civilian poseur-buyer, after which he was arrested, and drugs along with buy-bust money were recovered from him.
Defense's Argument
- Manalao claimed he was arrested on June 9, 2004, and denied selling drugs, asserting that he was merely handing an item to a friend.
- He admitted to having money on him but contested the circumstances of his arrest and the amount recovered.
RTC's Decision
- On July 26, 2005, the Regional Trial Court found Manalao guilty of both charges, imposing a life sentence for the sale of drugs and a separate indeterminate sentence for possession.
- The court ordered the confiscation of the seized drugs and directed the transfer of Manalao to the Bureau of Corrections.
Appeal to the Court of Appeals
- Manalao appealed the RTC's decision, arguing that the prosecution failed to prove his guilt beyond a reasonable doubt.
- The Court of Appeals affirmed the RTC's decision on November 27, 2008, rejecting Manalao's claims.
Supreme Court's Review
- The Supreme Court reviewed the case, focusing on whether the prosecution established the elements of illegal sale and possession of drugs.
- The Court found that the prosecution had sufficiently proven the sale of drugs through the testimony of the police officer involved in the buy-bust operation.
Elements of Illegal Sale of Drugs
- The Court reiterated that the prosecution must establish the identity of the buyer and seller, the object of the sale, and the delivery of the drugs.
- The evidence presented, including the identification of Manalao and the recovery of drugs, met the necessary legal standards.
Chain of Custody of Evidence
- The Court addressed the chain of custody requirements under Section 21 of Republic Act No. 9165, emphasizing that strict compliance is not always necessary as long as the integrity of the evidence is preserved.
- The prosecution demonstrated that the drugs were properly marked ...continue reading