Case Summary (G.R. No. 205007)
Key Dates and Applicable Law
The key dates include the RTC decision date on July 12, 2007, and the CA decision date on August 28, 2009. The applicable law for this case is Republic Act No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002, which delineates the penalties for drug offenses, including illegal sale and use of dangerous drugs.
Charges Against the Accused
On November 25, 2003, an information was filed against Manlangit for violating Section 5, Article II of RA 9165, which pertains to the illegal sale of dangerous drugs. The specific charge stated that on or about November 24, 2003, Manlangit willfully sold 0.04 grams of Methylamphetamine Hydrochloride (shabu). Subsequently, on December 11, 2003, another information was filed against him for using the same dangerous drug, which he tested positive for following his arrest.
Arraignment and Trial Proceedings
During the arraignment, Manlangit pleaded not guilty, and the cases were tried jointly. The prosecution presented evidence, including testimonies from law enforcement officers involved in a buy-bust operation conducted on November 24, 2003. The operation was initiated based on intelligence regarding a drug sale occurring in Makati, leading to the arrest of Manlangit, where he was found with drugs and marked money.
Defense and Claims by the Accused
Manlangit denied any involvement in the buy-bust operation, suggesting he was wrongfully identified and had been subjected to coercion and mistreatment by the police following his arrest. He asserted that the procedure followed during the arrest and the subsequent handling of evidence were flawed and raised concerns regarding the legal compliance of the operation.
RTC Decision
On July 12, 2007, the RTC found Manlangit guilty beyond reasonable doubt for both drug sale and drug use, imposing life imprisonment and a fine of 500,000 pesos for the former, along with a requirement for rehabilitation for the latter. Manlangit appealed this decision to the CA.
CA Ruling and Affirmation of Guilt
The CA upheld the RTC decision, rejecting Manlangit's claims regarding the prosecution's failure to prove his guilt. The court emphasized that the absence of prior surveillance or a test buy does not invalidate the legality of a buy-bust operation. It also concluded that Manlangit's defense was insufficient to counter the credibility of prosecution witnesses and the established evidence.
Legal Standards and Requirements for Conviction
The ruling reiterated the requirements for the prosecution of illegal drug sales, clarifying that proof of the transaction and the drug's identity are essential for conviction. The court cited relevant precedent confirming that the integrity of evidence and the credibil
...continue readingCase Syllabus (G.R. No. 205007)
The Case
- This case involves an appeal from the August 28, 2009 Decision of the Court of Appeals (CA) in CA-G.R. CR-H.C. No. 03273.
- The CA affirmed in toto the Decision dated July 12, 2007, of the Regional Trial Court (RTC) of Makati City.
- Accused-appellant Francisco Manlangit y Tresballes was found guilty of drug sale and drug use under Republic Act No. 9165, or the Comprehensive Dangerous Drugs Act of 2002.
The Facts
- On November 25, 2003, Manlangit was charged with violating Section 5, Article II of RA 9165 for allegedly selling 0.04 grams of Methylamphetamine Hydrochloride (shabu).
- A second charge was filed on December 11, 2003, for breaching Section 15, Article II of RA 9165, related to the unlawful use of dangerous drugs.
- During his arraignment, Manlangit pleaded not guilty, and the trials were conducted jointly.
- The prosecution presented evidence from a buy-bust operation conducted on November 24, 2003, initiated by the Makati Anti-Drug Abuse Council (MADAC) based on information from an informant.
- During the operation, Police Officer 2 Virginio Costa led a team that included MADAC operative Wilfredo Serrano as the poseur buyer.
- Manlangit was arrested following the transaction where he sold shabu to Serrano, and the marked money was recovered from his possession.
- Subsequent drug tests confirmed Manlangit's use of Methylamphetamine.
The Trial
- Manlangit denied the occurrence of the buy-bust operation, claiming he was wrongfully identified and subjected to coer