Case Summary (G.R. No. 126297)
Charges and Allegations
Fernando Santiago y Ibay was charged with the sale and possession of illegal drugs, specifically marijuana and shabu, as well as illegal possession of live ammunition. The charges dated back to May 6, 1989, where he allegedly sold shabu for P150.00 and possessed marijuana leaves and live ammunition without legal authority.
Proceedings and Evidence
During the trial, the prosecution presented testimonies from police officers involved in a buy-bust operation targeting Santiago, who was identified as a drug pusher based on community complaints. Police Officer Ancayan acted as the poseur buyer in the operation, wherein he allegedly purchased shabu from Santiago, leading to the latter’s arrest along with the recovery of an amount of buy-bust money, marijuana, and live ammunition. Forensic analysis confirmed the substances were illegal drugs.
Defense Presentation
The appellant denied the allegations, asserting that he was wrongfully arrested by police who came to his home. Santiago claimed that he did not possess any illegal drugs and that the ammunition belonged to a military acquaintance. He contended that he was coerced into signing documents and confessed to crimes he did not commit.
Trial Court’s Ruling
After hearing both sides, the Regional Trial Court found Santiago guilty of selling shabu but acquitted him of the charges of possessing marijuana and live ammunition due to insufficient evidence. He was sentenced to reclusion perpetua and fined P20,000. The court ordered the forfeiture of the confiscated items.
Appellate Arguments
The appellant argued that the prosecution failed to prove his guilt beyond a reasonable doubt and claimed inconsistencies in the testimonies of the police witnesses. Despite their testimonies lacking direct observation of the drug transaction, the court concluded that the act of selling illegal drugs was established through the successful buy-bust operation.
Credibility of Witnesses
The appellate court emphasized the principle that the sale of illegal drugs is consummated once the transaction is certified, focusing on the testimony of the poseur buyer. It was determined that the testimonies of the police officers were consistent and credible, supporting the conclusion of Santiago's guilt. The evidence indicated that illegal drugs were sold in exchange for money as detailed in the prosecution's case.
Sentencing and Legal Implications
The appellate court reiterated the legal stipulations governing sentencing for drug-related offenses. The court observed that the penalty of reclusion perpetua mandated life imprisonment without the option for subsidiary imprisonment if the imposed penalty exceeded certain
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Case Background
- The accused-appellant, Fernando Santiago y Ibay, was charged with violations of Republic Act No. 6425, known as the Dangerous Drugs Act of 1972, for the sale and possession of prohibited drugs in Criminal Cases Nos. 89-2515 and 89-2516, respectively.
- Additionally, he faced charges of illegal possession of live ammunition in Criminal Case No. 89-2517.
- The three informations were filed against the appellant regarding incidents that occurred on May 6, 1989, in Pasay City, Metro Manila.
Charges Filed
- Criminal Case No. 89-2515: Accused of possessing marijuana leaves without legal authority.
- Criminal Case No. 89-2516: Accused of selling Japanese Synthetic Cocaine (shabu) for P150.00.
- Criminal Case No. 89-2517: Accused of possessing 20 pieces of live M-16 rifle ammunition without a proper license or permit.
Trial Proceedings
- Upon arraignment, the accused pleaded not guilty.
- The prosecution presented witnesses including Emilia Rosaldez, Pat. George Baculinao, Pat. Ernesto Ancayan, and Pat. Luisito Silvano, detailing the buy-bust operation conducted on May 6, 1989.
- The police operation was initiated based on numerous complaints regarding the accused, who was identified as a drug pusher.
Prosecution's Evidence
- The operation was led by Capt. Gaudencio Cordora and involved surveillance, identifying the suspect, and executing the buy-bust.
- Patrolman Ancayan acted as the poseur buyer, who approached the accused to purchase shabu.
- After a brief interaction, the accused handed over an aluminum foil containing shabu in exchange f