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PEOPLE v. RAFAEL CUNANAN Y DAVID

FACTS:

On October 14, 2006, appellant Rafael Cunanan y David, also known as "Paeng Putol," was charged with the crime of illegal sale of dangerous drugs. The prosecution presented testimonies from several witnesses, including police officers PO1 Dario Gunda, Jr. and PO2 Michael Familara, who were involved in a buy-bust operation against the appellant. The police officers testified that they received information from a confidential informant regarding the appellant's involvement in drug selling. A buy-bust team was formed, with PO1 Gunda acting as the poseur-buyer. The team proceeded to the target area in Pasig City, where appellant was allegedly seen selling drugs. PO1 Gunda approached the appellant and purchased a small plastic sachet containing white crystalline substance believed to be shabu. After the transaction, the team arrested the appellant and recovered the marked money used for the transaction. The substance was sent for laboratory examination, which confirmed it to be methamphetamine hydrochloride or shabu. Appellant denied the charges and claimed that he was framed by the police officers. Defense witness Genedina Guevarra Ignacio testified that she witnessed the appellant being handcuffed by the police officers while watching a bingo game.

The Regional Trial Court found appellant guilty of violation of Section 5, Article II of Republic Act No. 9165 or the Comprehensive Dangerous Drugs Act of 2002 and imposed the penalty of life imprisonment and a fine of P500,000.00. The Court of Appeals affirmed the trial court's decision. Appellant then appealed to the Supreme Court, claiming, among others, that he was wrongfully arrested because he was not committing any crime at the time and that there were inconsistencies in the testimonies of the arresting officers.

ISSUES:

  1. Was there in flagrante delicto arrest in this case?

  2. Was it conceivable for the appellant to openly sell illegal drugs in the presence of many people?

  3. Did the apprehending officers comply with the proper custody guidelines for the seized dangerous drug?

  4. Were the testimonies of PO1 Gunda and PO2 Familara regarding the possession of the seized item conflicting?

RULING:

  1. The Court of Appeals affirmed the conviction of the appellant. The appeal was dismissed for lack of reversible error.

PRINCIPLES:

  • An in flagrante delicto arrest does not require the commission of the crime at the exact moment of arrest.

  • The presence of many people does not preclude the possibility of openly selling illegal drugs.

  • Compliance with the proper custody guidelines is required for the admissibility of seized dangerous drugs as evidence.

  • Conflicting testimonies regarding the possession of the seized item can cast doubt on its admissibility in court.