The Supreme Court affirmed the conviction of Ronald de Jesus and Amelito dela Cruz for violating Republic Act No. 9165, emphasizing the importance of credible witness testimony and adherence to chain of custody procedures in drug-related cases. The Court underscored that inconsistencies in testimonies on minor details do not invalidate the prosecution’s case if the core elements of the crime are proven beyond reasonable doubt, reinforcing the validity of buy-bust operations when conducted properly and the evidence is well-preserved.

Drug Bust or Frame-Up? Examining Evidence in Illegal Drug Sale and Possession

The case of People of the Philippines vs. Ronald de Jesus y Apacible and Amelito dela Cruz y Pua revolves around a buy-bust operation conducted by the District Anti-Illegal Drugs Special Task Force (DAID) following a tip about the illegal drug activities of Amel. The operation led to the arrest of De Jesus and Dela Cruz, who were subsequently charged with violating Section 5 (sale of dangerous drugs) and Section 11 (possession of dangerous drugs) of Republic Act (RA) No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002. The central legal question is whether the prosecution presented sufficient evidence to prove beyond reasonable doubt that the appellants committed these offenses, considering the defense’s claims of inconsistencies in the prosecution’s evidence and allegations of a frame-up.

The Regional Trial Court (RTC) convicted both appellants, a decision affirmed by the Court of Appeals (CA). The Supreme Court, in this appeal, examined the issues raised by the appellants, which primarily questioned the credibility of the prosecution’s witnesses, the inconsistencies in their testimonies, and the alleged absence of the corpus delicti. The appellants argued that the testimonies of the prosecution witnesses were inconsistent and that the chain of custody of the seized drugs was not proven with reasonable certainty, suggesting that the drugs presented in court may not have been the same ones seized during the operation. They also maintained that they were victims of a frame-up, alleging that the police officers had fabricated the charges against them.

The Supreme Court upheld the lower courts’ decisions, emphasizing that factual findings of the trial court, particularly regarding the credibility of witnesses, are entitled to great respect and will not be disturbed on appeal unless there is a clear showing that the trial court overlooked, misapprehended, or misapplied any fact or circumstance of weight and substance. The Court noted that the testimonies of the prosecution witnesses, particularly PO Hamdani and PO Paculdar, were clear, positive, and unequivocal regarding the buy-bust operation. PO Hamdani testified that he bought shabu from the appellants, while PO Paculdar testified that he found shabu in Dela Cruz’s possession. These testimonies were corroborated by documentary evidence, including the Pre-Operation Report, the marked P1,000.00 bill used as buy-bust money, and the Inventory Receipt signed by the appellants.

The Court also found that the inconsistencies pointed out by the appellants were trivial and did not negate the fact that a sale of shabu had taken place. Citing People of the Philippines v. Ricky Unisa y Islan, the Court reiterated that the sale of prohibited drugs is consummated upon delivery of the drugs to the buyer. The Court emphasized that what is material is proof that the transaction or sale actually took place, coupled with the presentation in court of evidence of corpus delicti. In this case, the prosecution presented evidence that PO Hamdani received shabu from Dela Cruz after giving the buy-bust money to De Jesus, thus establishing all the elements of the crime of illegal sale of dangerous drugs.

Regarding the possession charge against Dela Cruz, the Court found that all the essential elements of illegal possession of prohibited drugs were proven by the prosecution’s evidence. These elements include that the accused is in possession of an item or object identified as a prohibited drug, such possession is not authorized by law, and the accused freely and consciously possessed the said drug. PO Paculdar directly testified that Dela Cruz had two plastic sachets of shabu on his person when he was arrested, satisfying all these elements.

The Court also addressed the issue of the corpus delicti, stating that it was proven with reasonable certainty as the police substantially complied with the prescribed procedure under Section 21(a), Article II of RA No. 9165, its implementing rules, and the chain of custody rule. The Court emphasized that what assumes primary importance in drug cases is the prosecution’s proof, to the point of moral certainty, that the prohibited drug presented in court as evidence against the accused is the same item recovered from his possession. The Court found that the prosecution achieved this level of proof through evidence sufficiently establishing the links in the chain of custody of the seized shabu from the time of its seizure until it was presented in court.

The records showed that the plastic sachet containing shabu was immediately marked by PO Hamdani with his initials “AH” after it was confiscated from Dela Cruz. PO Hamdani had custody of the shabu until he turned it over to the desk officer who, in turn, handed it to the investigator. With respect to the shabu subject of the possession charge, PO Paculdar marked the two plastic sachets with his initials “EP” and “EP1,” and these were handled in a similar manner. The confiscated plastic sachets containing shabu were brought by PO Paculdar and other officers to the PNP Crime Laboratory for chemical examination, and the forensic chemist’s findings were stipulated upon by both parties.

The Supreme Court also emphasized that noncompliance with the prescribed procedure does not automatically render the seizure of the dangerous drug void and the evidence inadmissible. The law itself lays down certain exceptions to the general compliance requirement, stating that “as long as the integrity and the evidentiary value of the seized items are properly preserved by the apprehending officer/team,” the seizure of and the custody over the dangerous drugs shall not be rendered void and invalid. In this case, the prosecution proved that the integrity and the evidentiary value of the shabu seized from the appellants had been duly preserved under the precautionary handling measures the police undertook after the shabu was confiscated.

In conclusion, the Supreme Court dismissed the appeal and affirmed the decision of the Court of Appeals, finding appellants Ronald de Jesus and Amelito dela Cruz guilty of violating Section 5, Article II of Republic Act No. 9165, and appellant Amelito dela Cruz guilty of violating Section 11, Article II of Republic Act No. 9165. The Court’s decision underscores the importance of credible witness testimony, adherence to chain of custody procedures, and the principle that minor inconsistencies do not invalidate a conviction if the core elements of the crime are proven beyond reasonable doubt.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution presented sufficient evidence to prove beyond reasonable doubt that the appellants committed the offenses of illegal sale and possession of dangerous drugs, considering the defense’s claims of inconsistencies and a frame-up. The court focused on the credibility of the witnesses and the integrity of the chain of custody of the seized drugs.
What is a buy-bust operation?	A buy-bust operation is a recognized method used by law enforcement to trap and capture individuals involved in drug-related crimes. It involves an undercover officer posing as a buyer to purchase illegal drugs from a suspect, leading to their arrest.
What is meant by ‘corpus delicti’ in drug cases?	In drug cases, the ‘corpus delicti’ refers to the actual prohibited drug that is the subject of the crime. The prosecution must prove, to the point of moral certainty, that the substance presented in court is the same one recovered from the accused.
What is the chain of custody rule?	The chain of custody rule requires that the prosecution account for the movement of the seized drugs from the time of seizure until it is presented in court as evidence. This ensures the integrity and identity of the evidence.
What happens if there are inconsistencies in the testimonies of prosecution witnesses?	Inconsistencies in the testimonies of prosecution witnesses are not necessarily fatal to the prosecution’s case if they pertain to minor details and do not negate the core elements of the crime. The court assesses whether the overall evidence proves the accused’s guilt beyond a reasonable doubt.
What are the penalties for violating Section 5 and Section 11 of RA 9165?	Section 5 of RA 9165 (sale of dangerous drugs) carries a penalty of life imprisonment to death and a fine ranging from Five hundred thousand pesos (P500,000.00) to Ten million pesos (P10,000,000.00). Section 11 (possession of dangerous drugs) has varying penalties depending on the quantity of drugs involved.
Does noncompliance with the prescribed procedure under Section 21 of RA 9165 automatically invalidate a drug seizure?	No, noncompliance does not automatically invalidate the seizure if the integrity and evidentiary value of the seized items are properly preserved. The law allows for exceptions as long as the drugs’ integrity is maintained.
What is the significance of marking seized drugs?	Marking seized drugs immediately after confiscation is crucial to establish a clear chain of custody. This helps to ensure that the evidence presented in court is the same as what was seized from the accused.

This case highlights the importance of meticulous evidence handling and credible testimony in drug-related cases. The Supreme Court’s decision reinforces the principle that minor inconsistencies should not overshadow the established facts that prove the guilt of the accused, provided the integrity of the evidence is maintained and the chain of custody is properly documented.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: PEOPLE OF THE PHILIPPINES, APPELLEE, VS. RONALD DE JESUS Y APACIBLE AND AMELITO DELA CRUZY PUA, APPELLANTS., G.R. No. 191753, September 17, 2012