ROSANA ASIATICO Y STA. MARIA v. PEOPLE

FACTS:

Rosana Asiatico, along with her co-accused Aldrin Estrella, was charged with illegal possession of dangerous drugs under Republic Act No. 9165. The specific charge against Rosana was possession of a heat-sealed transparent plastic containing 0.05 grams of white crystalline substance, which tested positive for Methamphetamine Hydrochloride or "shabu." Rosana pleaded not guilty and the case proceeded to trial.

According to the prosecution's version, an informant reported the illegal drug trade of Rosana and Aldrin in Barangay Bagong Silang. A buy-bust operation was conducted, with Rosana identified as the seller of "shabu." During the operation, Rosana and Aldrin were arrested, and plastic sachets containing "shabu" were recovered from them. They were then taken to the hospital for examination and subsequently to the police station.

The defense presented a different version of events. Rosana and Aldrin claimed that armed policemen in civilian clothes forcibly entered and searched their house while they were there. They were accused of selling illegal drugs and taken to the police headquarters for questioning. The defense denied the allegations and stated that they only saw the drugs at the Drug Enforcement Unit office.

After trial, the Regional Trial Court (RTC) found Rosana and Aldrin guilty of illegal possession of drugs and sentenced them to twelve years and one day of imprisonment, as well as a fine of PhP 300,000. Rosana filed a Petition for Review on Certiorari before the Supreme Court seeking to reverse and set aside the RTC's decision.

ISSUES:

  1. Whether there was illegal possession of dangerous drugs.

  2. Whether the guilt of the accused was proven beyond reasonable doubt.

RULING:

  1. The Court of Appeals affirmed the conviction of the petitioner for illegal possession of dangerous drugs, finding that the elements of the crime were proven by the prosecution. The court held that the possession of the drugs was established through testimonial and documentary evidence, and there was no evidence to show that the drugs were planted or that the contraband did not belong to the petitioner.

  2. The guilt of the accused was proven beyond reasonable doubt. The court found that the prosecution presented credible witnesses and evidence, while the defense failed to present evidence to refute the allegations against the accused. The court emphasized that the credibility of the witnesses and the weight of the evidence presented are matters best addressed by the trial court.

PRINCIPLES:

  • In cases of illegal possession of dangerous drugs, the prosecution has the burden of proving beyond reasonable doubt the following elements: (a) the accused was in possession of the dangerous drugs; (b) the accused had knowledge or control over the drugs; and (c) the drugs were illegal or prohibited.

  • The credibility of witnesses and the weight to be given to their testimonies are matters best addressed by the trial court, which has the opportunity to observe their demeanor and assess their credibility based on firsthand knowledge of the case.