Case Summary (G.R. No. 247973)
Factual Background
On January 9, 2015, a buy-bust operation was organized by the Philippine National Police (PNP) Anti-Illegal Drugs Special Operations Task Force (AIDSOTF) based on reports from a confidential informant about illegal drug transactions. The designated poseur buyer, PO3 Junel Dela Cruz, along with back-up officer SPO2 Michael Calimlim, arranged to buy 300 grams of methamphetamine hydrochloride, commonly known as shabu, for P300,000, planned for execution the following day at a fast-food restaurant in Quezon City.
At the agreed upon time, Tamundi approached the undercover officers after they had arrived at the target location. Upon confirming the money from PO3 Dela Cruz, Tamundi handed over a black paper bag containing the drugs in exchange for the buy-bust money. Following the transaction, she was arrested by the police, and the confiscated items underwent proper documentation, including marking and inventory in the presence of witnesses from the media and local government.
RTC Ruling
The RTC convicted Tamundi on September 17, 2018, sentencing her to life imprisonment and imposing a fine of P500,000. The court found that the prosecution had successfully proven all elements required for a conviction under the law, including the identities of the buyer and seller, the object of the sale being shabu, and the actual delivery of the drug in exchange for the money. Tamundi's defense was deemed insufficient, lacking corroborating witnesses, and the court noted the presumption of regularity in the actions of law enforcement officers during the operation.
CA Ruling
Tamundi subsequently appealed to the Court of Appeals (CA), which affirmed the RTC ruling on June 29, 2020. The CA reiterated that the conviction would stand as long as there was credible proof of the sale and the physical evidence linking the accused to the crime, confirming the testimonies of the buy-bust team as reliable. Despite Tamundi's arguments regarding the chain of custody and procedural deviation, the CA concluded that the prosecution adequately established that the contraband was handled according to the established laws regarding drug transactions.
Issues Presented
The primary issue focused on whether Tamundi was guilty of illegal sale of dangerous drugs as charged. The legal determination required the court to establish that the elements of the crime were met, including the identity of the seller and buyer, the transaction, and the object and consideration.
Court's Ruling
The Supreme Court ultimately found the appeal without merit. It underscored the necessity of proving the actual sale and the corpus delicti of the crime—the seized drugs. The testimonies provided by the police clearly identified Ta
...continue readingCase Syllabus (G.R. No. 247973)
Case Overview
- This case involves an ordinary appeal by Nadjera Tamundi y Pamlian (accused-appellant) against the Decision of the Court of Appeals (CA) affirming her conviction for illegal sale of dangerous drugs, specifically methamphetamine hydrochloride (shabu), under Section 5, Article II of Republic Act No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002.
- The original ruling by the Regional Trial Court (RTC) of Quezon City sentenced Tamundi to life imprisonment and a fine of P500,000.00.
Facts of the Case
- An Information was filed against Tamundi alleging that on January 10, 2015, she sold 295.53 grams of methamphetamine hydrochloride without legal authorization.
- The prosecution presented evidence that on January 9, 2015, a buy-bust operation was initiated based on intelligence reports regarding Tamundi's involvement in drug sales.
- During the operation, Police Officer 3 (PO3) Junel Dela Cruz acted as the poseur buyer and was instructed to purchase 300 grams of shabu for P300,000.00.
- The transaction took place in front of a Burger King in Quezon City where Tamundi allegedly provided the drugs in exchange for the buy-bust money, which included marked bills.
- Tamundi was arrested shortly after the transaction, and the evidence was marked and inventoried in the presence of witnesses, although a media representative refused to sign the invento