Facts:
Ramon Arcilla, Jimmy Salazar, and Reynaldo Peralta were charged with violations of Section 2(e)(f)(m)(q), Article 1 in relation to Section 21 of Republic Act No. 6425, as amended, for illegal possession and sale of prohibited drugs specifically “shabu” (methamphetamine hydrochloride) and marijuana.
On March 1, 1996, in the City of Manila, according to the testimony of SPO1 Rodolfo Samoranos, a buy-bust operation was conducted in Arcilla’s residence after a surveillance operation confirmed narcotics activities based on a report from the local Barangay Chairman. During the operation, Arcilla and Salazar were accused of selling “shabu” and marijuana based on their possession of said substances when the arrest was made. Peralta was also arrested for the illegal possession of “shabu,” an improvised tooter, and aluminum foils with trace elements of methamphetamine hydrochloride.
The defendants claimed that no actual buy-bust operation transpired and that a warrantless search was conducted wherein the authorities planted the prohibited substances and arrested them. The defendants also argued that crucial evidence was obtained through an illegal search and should therefore be deemed inadmissible, and the evidence for the prosecution was insufficient as it relied on planted items and hearsay from a barangay chairman who was not presented as a witness.
Issues:
1. Whether a legitimate buy-bust operation occurred, as opposed to the defendant’s claim of illegal search and planted evidence.
2. The admissibility of evidence obtained during the operation.
3. Whether the ownership of the illegal substances was sufficiently established.
4. The credibility of police testimony and the defense claim of fabrication and warrantless arrest.
5. The relevance of the barangay chairman’s testimony and the defendant’s alleged coercion into admitting ownership of the drugs.
Court’s Decision:
The Supreme Court affirmed the decision of the Court of Appeals which had earlier affirmed with modifications the decision of the Regional Trial Court. The Supreme Court held that:
1. The testimonies of the police officers, particularly SPO1 Rodolfo Samoranos, were credible and provided a detailed account of a valid buy-bust operation, not a planted evidence scenario.
2. Evidence obtained from the operation was admissible and not the product of an illegal search. The search was incident to a lawful arrest.
3. The ownership of the drugs was irrelevant because mere possession without legal authority is punishable under the law.
4. Claims of frame-up or extortion by the police in drug cases require substantive proof, which the petitioners failed to present.
5. The non-presentation of the barangay chairman as a witness did not weaken the prosecution’s case, as his testimony would have been merely corroborative and not indispensable.
Doctrine:
In drug-related offenses, the prosecution need not prove ownership of the illegal drugs, as mere unauthorized possession is punishable by law. Also, a credible and detailed police testimony can be the basis for conviction in a buy-bust operation. Lastly, claims of frame-ups in drug cases must be proven with clear and convincing evidence, and the failure to present a witness whose testimony would only be corroborative does not necessarily weaken the prosecution’s case.
Historical Background:
The case arose from the efforts of Philippine law enforcement to curb drug-related crimes within the jurisdiction. Buy-bust operations are commonly utilized by Philippine authorities to apprehend individuals involved in illegal drug transactions. The case reflects the challenges of establishing the credibility of police operations amidst allegations of misconduct like evidence planting, and how the judiciary approaches the evaluation of evidence and witness testimony in such scenarios.
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