PEOPLE v. ZALDY SIOSON Y LIMON

FACTS:

Zaldy Sioson, the accused-appellant, is appealing the decision of the Court of Appeals, which affirmed the Regional Trial Court's finding of guilt against him for violating Sections 5 and 11 of Republic Act (R.A.) No. 9165 or the "Comprehensive Dangerous Drugs Act of 2002." Sioson was charged with illegal sale and illegal possession of dangerous drugs.

The charges against Sioson were based on a buy-bust operation conducted by the police. The operation was initiated following a tip from a confidential asset. During the operation, Sioson allegedly sold one plastic sachet of shabu to a police officer in exchange for money. In addition, four other plastic sachets were found in his possession.

The items seized during the operation were duly marked in the presence of Sioson and witnesses before being sent to the crime laboratory for testing. The tests confirmed that the sachets contained shabu.

Sioson claimed that he was framed and physically assaulted by the police officers before being brought to the municipal hall. However, the Regional Trial Court found him guilty as charged. The Court of Appeals upheld the RTC's decision, stating that Sioson's defense of frame-up and alibi were insufficient to disprove the evidence against him.

Sioson then appealed to the Supreme Court.

ISSUES:

  1. Whether or not the accused-appellant is guilty beyond reasonable doubt for violating Sections 5 and 11, Article II of the Comprehensive Dangerous Drugs Act.

RULING:

  1. The Court affirms the ruling of the RTC and the CA that the accused-appellant is guilty beyond reasonable doubt for violating Sections 5 and 11, Article II of the Comprehensive Dangerous Drugs Act. The prosecution was able to prove all the elements of the crime of illegal sale and illegal possession of dangerous drugs and establish the identity, integrity, and probative value of the seized drugs. The defense of frame-up and alibi presented by the accused-appellant were deemed unsubstantiated and the presumption of regularity in the performance of official duties was upheld.

PRINCIPLES:

  • The elements of the crime of illegal sale and illegal possession of dangerous drugs must be proven beyond reasonable doubt.

  • The identity, integrity, and probative value of the seized drugs must be preserved and kept intact by the evidence custodian until its presentation in court.

  • The defense of frame-up and alibi must be substantiated to be considered valid.

  • The presumption of regularity in the performance of official duties is upheld in the absence of clear and convincing evidence to the contrary.