Case Summary (G.R. No. 136374)
Factual Background
On March 13, 2003, a buy-bust operation was conducted in Pasig City after the local Mayor's Special Action Team received reports that an individual known as "Kirat," identified as Rivera, was openly selling prohibited drugs. The operation was led by P/Insp. Rodrigo E. Villaruel of the Pasig Philippine National Police. During the operation, PO3 Salisa was introduced to Rivera as a buyer and subsequently handed him two heat-sealed sachets containing a white crystalline substance in exchange for P200. The transaction resulted in Rivera's arrest, whereupon two plastic sachets were labeled with specific markings for evidence.
Initial Legal Proceedings
The trial court, upon examination of the prosecution's evidence including testimonies from police officers involved in the buy-bust operation, convicted Rivera on January 23, 2004. He was sentenced to life imprisonment and ordered to pay a fine of P500,000. Rivera maintained his innocence, arguing that he was a victim of an illegal arrest and was framed by the police.
Appellate Proceedings
Rivera's appeal to the Court of Appeals was met with affirmation of the trial court's decision on August 14, 2006. He subsequently raised concerns regarding the legality of his arrest without a warrant and questioned the sufficiency of evidence supporting his conviction.
Law on Arrest Without Warrant
Rivera contested the validity of his arrest on the basis that it was made without a warrant. However, established jurisprudence indicates that where an individual is arrested while committing an offense, a warrantless arrest is permissible under Rule 113, Section 5(a) of the Rules of Court. The court noted that Rivera’s voluntary participation in the legal process after his arrest constituted a waiver of his constitutional protection against illegal arrests.
Evidence and Burden of Proof
The appellate court emphasized that evaluating witness credibility is primarily a function of the trial court, which is in a better position to assess the demeanor and reliability of witnesses. The court held that the testimony of the police officers was credible and confirmed Rivera's guilt beyond a reasonable doubt. Rivera's claims of police coercion and extortion were dismissed as unsubstantiated, particularly in light of the absence of any supporting evidence or complaints from bystanders.
Compliance with Legal Procedures
In addressing Rivera's argument regarding the alleged non-compliance with Section 21 of R.A. 9165 regarding the chain of custody and handling of the seized drugs, the court affirmed that the integrity
...continue readingCase Syllabus (G.R. No. 136374)
Case Overview
- This case involves the appeal of Willie Rivera (appellant) against his conviction for violating Republic Act No. 9165, specifically Section 5, Article II, concerning the illegal sale of dangerous drugs.
- The appeal was processed through various judicial levels, culminating in a decision by the Court of Appeals on August 14, 2006, which affirmed the Regional Trial Court's conviction.
Factual Background
- The Information against Rivera stated that on March 13, 2003, in Pasig City, he unlawfully sold two heat-sealed sachets containing a white crystalline substance identified as methylamphetamine hydrochloride (shabu) to a police poseur-buyer, PO3 Amilassan M. Salisa.
- The operation was initiated by the Pasig City Mayor's Special Action Team based on a tip-off regarding a person identified as "Kirat" engaged in drug selling.
The Buy-Bust Operation
- A buy-bust team was formed under P/Insp. Rodrigo E. Villaruel, comprising several police officers, including PO3 Salisa as the poseur buyer.
- PO3 Salisa received two marked P100 bills from P/Insp. Villaruel, on which he inscribed his initials above the serial numbers.
- The operation took place at approximately 12:55 PM, where PO3 Salisa identified Rivera as "Kirat" after being pointed out by an informant.
- Upon completion of the transaction, where Rivera handed over two sachets in exchange for the marked bills, the police team apprehended him, informing him of his rights and placing markings on the seized items.