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FIRST DIVISION PEOPLE v. LOUIE CATALAN Y DEDALA

FACTS:

Louie Catalan was arrested during a buy-bust operation for selling shabu to a police officer poseur-buyer. He was convicted by the Regional Trial Court (RTC) and sentenced to life imprisonment and fined P500,000.00. The Court of Appeals (CA) affirmed his conviction. In his appeal to the Supreme Court, Catalan seeks exoneration and acquittal.

The Prosecution's version of events states that on February 8, 2004, a civilian informant tipped off the police about Catalan's drug-selling activities. The buy-bust team, led by PO1 Alaindelon Ignacio, conducted an operation in a billiard hall. Ignacio posed as a buyer and handed Catalan P100.00 as buy-bust money. After Catalan handed a plastic sachet to Ignacio, the latter identified himself as a police officer, tried to apprehend Catalan, but the latter managed to escape. Ignacio caught up with him, frisked him, and found another plastic sachet and the buy-bust money. The confiscated items were brought to the police station and subsequently submitted for laboratory examination, which confirmed the presence of shabu.

The Defense argued that Catalan had been framed. Catalan claimed that three men barged into his house, conducted a search, and accused him of selling drugs. They handcuffed him and brought him to their office, demanding P40,000.00 for his release. When he refused to pay, they took him to the police station.

The RTC found Catalan guilty based on his denial and failure to offer a plausible explanation for his possession of the prohibited drug. The court also noted that Catalan did not present his live-in partner as a corroborating witness, nor did he file any case against the police officers for filing a fabricated charge against him.

ISSUES:

  1. Whether the minor inconsistencies in the witness's testimony affect his credibility.

  2. Whether the defense of alibi and denial is viable in this case.

  3. Whether the Prosecution complied with the requirement of proving the violation of Section 5 of Republic Act No. 9165

  4. Whether the buy-bust team adhered to the statutory procedure on chain of custody

  5. Whether the Prosecution has discharged its burden of proof in establishing the commission of the crime charged and identifying the accused as the perpetrator.

  6. Whether the lower courts erred in relying on the presumption of regularity in the performance of duty by the arresting lawmen.

RULING:

  1. The minor inconsistencies in the witness's testimony do not affect his credibility. These slight contradictions in a witness's testimony show that it was not rehearsed but are badges against memorized perjury. Affidavits, such as a "Sinumpaang Salaysay" or a sworn statement, are generally subordinated in importance to open court declarations. Therefore, the credibility of the witness is strengthened rather than destroyed by these minor inconsistencies.

  2. The defense of alibi and denial is considered inherently weak and constitutes an "unstable sanctuary for felons" because it can be easily concocted. In this case, the accused could only offer denial and alibi that he was eating at home when he was arrested. Between the positive and categorical narration made by the witness and the negative averments of the appellant, the former is entitled to greater weight. Thus, the defense of alibi and denial is not viable in this case.

  3. The Prosecution failed to comply with the requirement of proving the violation of Section 5 of Republic Act No. 9165 because of substantial gaps in the chain of custody of the seized dangerous drugs, raising doubts about the authenticity of the evidence presented in court.

  4. The buy-bust team did not adhere to the statutory procedure on chain of custody as they failed to properly mark the seized drugs, there was absence of a media or Department of Justice representative or an elected public official during the arrest and seizure, the investigator who made the marking was not presented as a witness, and no physical inventory or photographs were taken of the seized drugs.

  5. The Prosecution has not discharged its burden of proof beyond reasonable doubt in establishing the guilt of the accused. The weakness of the defense put up by the accused is inconsequential as long as the Prosecution has not overcome the presumption of innocence in favor of the accused.

  6. The lower courts committed gross error in relying on the presumption of regularity in favor of the arresting lawmen. The presumption of regularity could not prevail over the presumption of innocence, and where there are indications of serious lapses committed by the arresting lawmen, there can be no presumption of regularity.

PRINCIPLES:

  • Minor inconsistencies in a witness's testimony do not affect credibility and may even strengthen it.

  • Affidavits are generally subordinate in importance to open court declarations.

  • The defense of alibi and denial is considered inherently weak and easily concocted.

  • The Prosecution bears the burden to establish the guilt of the accused beyond reasonable doubt and must prove each and every element of the crime charged.

  • The chain of custody is vital to a judgment of conviction in drug-related cases and non-compliance with the requirements of preserving the integrity of the chain of custody can undermine the credibility of the evidence presented in court.

  • The Prosecution must prove the commission of the offense charged and the participation of the accused beyond reasonable doubt.

  • The accused has no burden of proof in establishing his innocence and must be acquitted if the Prosecution fails to overcome the presumption of innocence.

  • The presumption of regularity in the performance of duty by law enforcement officers cannot prevail over the presumption of innocence of the accused if there are indications of serious lapses committed by the officers.