**Facts:** The case revolves around Larry Lopez, charged with two violations under Republic Act No. 9165 (RA 9165), otherwise known as the Comprehensive Dangerous Drugs Act of 2002. In Criminal Case No. 3188, Lopez was accused of selling 0.06 grams of shabu to a poseur buyer for PHP300.00 without authorization. In Criminal Case No. 3189, Lopez faced charges for possessing 6.20 grams of marijuana without a permit or license. Despite pleading not guilty, after trial, the Regional Trial Court (RTC) of Baler, Aurora, found Lopez guilty for both charges, imposing life imprisonment and a fine for the shabu sale and fourteen (14) years of imprisonment plus a fine for the marijuana possession.
The prosecution narrated that on November 1, 2003, following a tip about Lopez’s illegal activities, a buy-bust operation was executed leading to his apprehension and the seizure of the drugs. Meanwhile, Lopez contended his innocence, claiming he was framed by off-duty officers and that he was just driving his tricycle to the cemetery with passengers at the time of the alleged arrest.
Lopez appealed the RTC’s decision to the Court of Appeals (CA) which affirmed the RTC’s decision. Unsatisfied, Lopez took his appeal to the Supreme Court alleging inconsistencies in the testimonies regarding the buy-bust operation and contesting the validity of the warrantless search that led to the marijuana seizure.
**Issues:**
1. Whether the inconsistencies in the police testimony affect the integrity of the prosecution’s evidence.
2. Whether the warrantless search and seizure that resulted in the marijuana’s discovery was legal.
3. Proper imposition of penalties under RA 9165.
**Court’s Decision:** The Supreme Court dismissed the appeal, finding no merits to overturn the CA and RTC’s decisions. It held that:
– Minor inconsistencies in witness testimony do not undermine the credibility of the witnesses or the operations. These inconsistencies were not related to the critical aspects of the buy-bust operation itself.
– The defense of frame-up was not sufficiently proven, lacking evidence of improper motive from police officers.
– The warrantless arrest and subsequent search were deemed lawful as they were conducted in the immediate aftermath of a crime, making the seized marijuana admissible evidence.
– While affirming the guilt of Lopez for both charges, the Supreme Court modified the penalty for the marijuana possession to an indeterminate sentence of twelve (12) years and one (1) day as the minimum to twenty (20) years as the maximum, in line with the Indeterminate Sentence Law.
**Doctrine:** The decision reiterates the validity of buy-bust operations as a legitimate form of entrapment and a means of apprehending drug law violators. It also clarifies the application of the Indeterminate Sentence Law in cases involving violations of RA 9165, setting precedent on penalty imposition for drug possession.
**Class Notes:**
– **Buy-Bust Operation Validity:** Recognized as a legitimate law enforcement technique to apprehend drug violators in the act.
– **Witness Testimony:** Minor inconsistencies that don’t relate to the essence of the event in question do not diminish the credibility of the witnesses or the operability of the operation.
– **Warrantless Arrest:** Legal if conducted immediately after the commission of the crime, pursuant to Section 5, Rule 113 of the Revised Rules of Criminal Procedure.
– **Search and Seizure Without Warrant:** Permissible as a consequence of a lawful arrest where the search yields evidence of the crime.
– **Indeterminate Sentence Law Application:** Requires the imposition of a range between a maximum and a minimum penalty for non-Code offenses, altering the common practice of fixed-term sentencing for drug convictions.
**Historical Background:** The legality and procedural correctness of buy-bust operations and the principles governing warrantless arrests and searches in drug enforcement have been subject to long-standing debates and litigation. This case reaffirms critical legal principles about the war against illegal drugs in the Philippines, setting guidelines on the conduct of entrapment operations, the admissibility of seized evidence, and the imposition of penalties.
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