Case Summary (G.R. No. 33380)
Factual Background of the Case
Daniel Sibunga y Agtoca was charged with violating Section 5, Article II of Republic Act No. 9165. The prosecution alleged that on September 26, 2003, Sibunga, without legal authority, sold a medium heat-sealed plastic sachet containing methamphetamine hydrochloride (shabu) in Baguio City. The operation was conducted after police received a tip-off regarding drug sales by Sibunga and an accomplice named "Marty." A buy-bust operation ensued, leading to the arrest of both individuals shortly after the exchange of the drug for cash (referred to as "show money").
Evidence Presented at Trial
The prosecution's evidence included the testimonies of police officers involved in the buy-bust operation, who positively identified Sibunga as one of the sellers. The officers testified that the drug was seized, and subsequent laboratory tests confirmed the substance as shabu. The prosecution established the timeline, with surveillance and coordination with the Philippine Drug Enforcement Agency (PDEA). The accused was apprehended immediately after the transfer of the sachet.
Defense Claims
In his defense, Sibunga contended that he was framed for the crime. He claimed that he was merely in Baguio playing billiards when the police apprehended him without cause. He asserted that no actual sale occurred since no payment was exchanged for the drug during the operation, thus disputing the elements necessary for conviction under the law.
Trial Court's Ruling
On January 24, 2006, the Regional Trial Court found Sibunga guilty, sentencing him to life imprisonment and imposing a fine of P500,000. The court emphasized the credibility of the police officers' testimonies and established the presence of necessary elements for conviction beyond reasonable doubt.
Appellate Court’s Findings
Sibunga appealed the ruling, raising concerns about inconsistencies in the testimonies of the officers regarding the weight of the drug and the denominations of the show money. The Court of Appeals, in its decision dated June 1, 2007, affirmed the trial court's ruling, stating that minor inconsistencies did not undermine the core credibility of the witnesses. The appellate court further dismissed the argument that the absence of payment negated the sale, asserting that a buy-bust operation does not require immediate monetary exchange as long as evidence of the drug exists.
Review and Conclusion
Upon review, the Supreme Court upheld the findings of the lower courts. It highlighted that
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Case Background
- The case revolves around the conviction of Daniel Sibunga y Agtoca for violating Section 5, Article II of Republic Act No. 9165, known as the Comprehensive Dangerous Drugs Act.
- The Information filed against the appellant states that on September 26, 2003, in Baguio City, he unlawfully sold, distributed, and/or delivered a medium heat-sealed plastic sachet containing methamphetamine hydrochloride (shabu), weighing 2.01 grams.
Prosecution's Version
- On the evening of September 26, 2003, police officers conducted surveillance in People's Park, Baguio City, after receiving a tip about individuals looking for buyers of shabu.
- A buy-bust operation was organized, with instructions from Inspector Melchor Nawi Ong, and a team was formed, including PO3 Albert Lag-ey and PO2 Vincent Lagan, who received P8,000.00 as "show money."
- At approximately 7:15 p.m., the team met their informant and proceeded to U Need Lumber, where the two suspects, including the appellant, were approached.
- The operation culminated in the arrest of the appellant after he was identified as one of the individuals involved in the transaction, during which the police officers presented themselves and seized the sachet of shabu.
Appellant's Defense
- The appellant claimed he was framed, alleging he was merely