Title
Supreme Court
People vs. Usman y Gogo
Case
G.R. No. 201100
Decision Date
Feb 4, 2015
Accused-appellant convicted for illegal shabu sale during buy-bust; warrantless arrest valid, chain of custody upheld despite lapses; frame-up claim dismissed.

Case Summary (G.R. No. 201100)

Charges and Proceedings

Mhods Usman was charged with violating Section 5, Article II of Republic Act No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002, for allegedly selling 0.068 grams of shabu without legal authorization. He pleaded not guilty upon arraignment, and a series of pre-trial stipulations were made concerning the identity of the accused and the jurisdiction of the court.

Prosecution's Evidence

The prosecution presented testimonies from various police officers involved in the operation. PO1 Joel Sta. Maria described how a confidential informant alerted them to Usman's illegal activities, prompting a buy-bust operation. Officers prepared marked money, identified Usman, and executed the operation whereby Usman was caught in the act of selling shabu, handing over a plastic sachet in exchange for money. The evidence was subsequently turned over to the crime laboratory, where it tested positive for methamphetamine.

Defense and Claims

In defense, Usman claimed he was framed by the police and highlighted an alleged lack of compliance with procedural requirements during his arrest. He asserted that he was in his home when arrested, and the police purportedly ransacked his house and demanded a bribe for his release. He denied any prior connection with the arresting officers.

Court's Ruling

The Regional Trial Court (RTC) convicted Usman, imposing life imprisonment and a fine of P500,000. Usman appealed, asserting several errors regarding the legality of his warrantless arrest and the alleged violation of his rights under Republic Act No. 7438, as well as the handling of the seized items per the requirements of Republic Act No. 9165.

Appellate Court's Affirmation

The Court of Appeals (CA) upheld the RTC decision, determining that Usman's arrest was valid due to being caught in the act of committing a drug offense and that there was substantial compliance with the legal requirements concerning the drug’s handling and the arrest itself. It also rejected his claims of being framed, emphasizing that no evidence supported such assertions.

Supreme Court's Assessment

Upon further review, the Supreme Court dismissed Usman's appeal. It clarified that objections regarding the legality of arrest must be made before arraignment; Usman's failure to do so constituted a waiver of h

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