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PEOPLE v. DARLENE QUIGOD Y MIRANDA

FACTS:

On September 6, 2002, the Philippine Drug Enforcement Agency (PDEA) received information about accused-appellant Darlene Quigod selling "shabu" in Butuan City. A team was formed to conduct a buy-bust operation, with SPO2 Jamila acting as the poseur-buyer. Accused-appellant agreed to sell two sachets of shabu to SPO2 Jamila. After examining the articles, SPO2 Jamila signaled the team to arrest accused-appellant. The team brought accused-appellant to their office and seized the two sachets of shabu, which were later confirmed to be methamphetamine hydrochloride by a laboratory examination. Accused-appellant claimed to be a police asset conducting surveillance on suspected drug dealers and denied participation in the buy-bust operation.

Accused-appellant appealed her conviction for violation of the Comprehensive Dangerous Drugs Act and argued that her guilt was not proven beyond reasonable doubt and questioned the chain of custody of the confiscated drugs. The Court of Appeals affirmed the trial court's decision, stating that all elements of the offense were proven, including the chain of custody. SPO2 Jamila identified accused-appellant as the seller, and the examination of the seized drugs confirmed their nature. The CA also held that accused-appellant's denial was self-serving and had little weight in law.

Accused-appellant filed a Notice of Appeal, and although given the opportunity, the prosecution did not file a supplemental brief. Accused-appellant, however, filed a Supplemental Brief, raising various issues, including the failure to prove her guilt beyond reasonable doubt, non-compliance with the custody requirements under RA 9165, and the failure to prove the integrity of the seized drug.

ISSUES:

  1. Whether the factual findings of the trial court, affirmed by the CA, are binding and conclusive upon the Supreme Court.

  2. Whether the buy-bust operation conducted by the police officers was valid.

  3. Whether the chain of custody of the prohibited drugs was properly established.

  4. The issue in this case is whether the elements of the crime of illegal sale of prohibited drugs were proven, and whether the chain of custody of the confiscated drugs was properly established.

  5. Whether there was an unbroken chain in the custody of the prohibited drug.

  6. Whether the defense of denial is weak and insufficient to engender reasonable doubt.

  7. Whether there was any inconsistency, contradiction, or fabrication in the testimony of the prosecution witness.

RULING:

  1. The Supreme Court sustains the conviction of the accused-appellant. The factual findings of the trial court, especially when affirmed by the CA, are generally binding and conclusive upon the Supreme Court.

  2. The buy-bust operation conducted by the police officers was valid. The evidence establishes that it was the police informant who made contact with the accused-appellant and introduced SPO2 Jamila as a buyer for drugs. The accused-appellant agreed to sell shabu to SPO2 Jamila, went to retrieve the drugs, and was subsequently arrested. The court reiterates that a buy-bust operation is a legitimate mode of apprehending drug pushers, provided constitutional and legal safeguards are followed.

  3. The chain of custody of the prohibited drugs was properly established. The essential elements of the illegal sale of prohibited drugs were proven by the prosecution. The drugs were seized and identified as prohibited drugs, and there was an actual exchange of marked money and the contraband. The accused-appellant was fully aware that she was selling and delivering a prohibited drug.

  4. The Court ruled in favor of the prosecution. The elements of the crime of illegal sale of prohibited drugs were proven in this case. The testimony of the police officer established that a sale occurred between the accused-appellant and himself for Php 2,000 worth of shabu.

  5. The Court also found that the chain of custody of the confiscated drugs was properly established. The testimony of the police officer and the forensic chemical officer from the PNP Crime Laboratory showed that the drugs were immediately seized, confiscated, and submitted for examination. There was substantial compliance with the law, and the integrity of the drugs was preserved.

  6. Yes, there was an unbroken chain in the custody of the prohibited drug. The forensic examiner testified that she conducted the laboratory examination and the results were consolidated into an official chemistry report, which was in the possession of the court. This testimony establishes the continuity of custody of the prohibited drug.

  7. The defense of denial is weak and insufficient to engender reasonable doubt. The court held that bare denial is inherently weak and viewed with disfavor. The defendant's denial is considered self-serving and can be easily concocted. In this case, the prosecution presented convincing evidence of guilt, including the positive testimony of a witness. Therefore, the defense of denial is not enough to create reasonable doubt.

  8. No, there was no inconsistency, contradiction, or fabrication in the testimony of the prosecution witness. The analysis of the testimony of the witness shows that there were no inconsistencies or contradictions. Moreover, the witness testified that he did not know the accused-appellant prior to the incident. Therefore, the presumption of regularity in the performance of duty applies, and there is no reason to doubt the witness's credibility.

PRINCIPLES:

  • Factual findings of the trial court, affirmed by the CA, are binding and conclusive upon the Supreme Court unless there is a clear showing of arbitrariness, capriciousness, or palpable error.

  • A buy-bust operation is a legitimate mode of apprehending drug pushers if constitutional and legal safeguards are observed.

  • The essential elements of the illegal sale of prohibited drugs are the accused selling and delivering a prohibited drug to another, and knowing that the substance sold and delivered is a prohibited drug.

  • Proper inventory, marking, and preservation of seized drugs are required to establish the chain of custody and ensure the integrity of the evidence.

  • Corpus delicti is the body or substance of the crime, and establishes the fact that a crime has actually been committed.

  • In every prosecution for the illegal sale of prohibited drugs, the presentation of the drug as evidence in court is material.

  • The chain of custody requirement ensures the establishment of the identity of the prohibited drug beyond doubt and removes unnecessary doubts concerning the identity of the evidence.

  • Non-compliance with the provisions of Section 21 of the Implementing Rules and Regulations of R.A. 9165 does not render the arrest illegal or the items seized inadmissible as long as the integrity and evidentiary value of the seized items are properly preserved.

  • Substantial compliance with the law and the proper preservation of the integrity of the seized items are essential for their admissibility as evidence in determining the guilt or innocence of the accused.

  • Unbroken chain of custody is required to establish the integrity and evidentiary value of seized items.

  • Denial is an inherently weak defense and must be substantiated by convincing evidence.

  • Presumption of regularity in the performance of duty applies in the absence of any intent to falsely impute a crime against the accused.