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PEOPLE v. EMMANUEL OLIVA Y JORJIL

FACTS:

The Chief of Station Anti-Illegal Drugs - Special Operations Task Group (SAID-SOTG) received information about the sale of dangerous drugs by a person called "Manu" in Barangay Cembo, Makati City. A buy-bust operation was planned and a team was formed. PO3 Marcelo acted as the poseur-buyer and given marked money, while PO1 Catabay acted as backup. The team went to the location given by a confidential informant.

At the target area, the informant pointed out Emmanuel Oliva as "Manu," the seller of dangerous drugs. PO3 Marcelo and the informant approached Oliva, and after being introduced as a buyer, PO3 Marcelo handed Oliva the marked money. Oliva then showed PO3 Marcelo four sachets containing a white substance believed to be shabu. Two other persons, Bernardo Barangot and Mark Angelo Manalastas, were also present and each took one sachet from Oliva.

After the transaction, PO3 Marcelo signaled to his back-up by scratching his chin. The police then arrested Oliva and Barangot. PO1 Catabay arrived and arrested Manalastas. Oliva was found with another sachet, marked money, and two P500.00 bills during a body search. The appellants were taken to the barangay hall where an inventory was conducted, leading to the preparation of an inventory report. The items were marked, photographed, and submitted to the PNP Crime Laboratory for examination. The substance in the sachets tested positive for methamphetamine hydrochloride. As a result, Oliva was charged with the sale of dangerous drugs, while Oliva, Barangot, and Manalastas were charged with possession of dangerous drugs.

ISSUES:

  1. Whether the accused is guilty of Violation of Sections 5 and 11 of Republic Act No. 9165.

  2. Whether the seized items are admissible as evidence.

RULING:

  1. The Court ruled that the accused is guilty of Violation of Sections 5 and 11 of Republic Act No. 9165. The prosecution was able to establish the elements of the said offenses beyond reasonable doubt. The accused were caught in flagrante delicto selling and possessing dangerous drugs.

  2. The Court ruled that the seized items are admissible as evidence. The chain of custody of the seized items was properly established. There was testimonial and documentary evidence showing that the items seized from the accused were the very same items submitted for laboratory examination.

PRINCIPLES:

  • Violation of Sections 5 and 11 of Republic Act No. 9165 require proof beyond reasonable doubt of the elements of the offenses.

  • The chain of custody of seized items must be preserved to ensure the integrity and evidentiary value of the items.

  • Testimonial and documentary evidence may be used to establish the chain of custody.