Saturday, July 27, 2013

G.R. No. 124346, June 8, 2004 YOLLY TEODOSIO y BLANCAFLOR v. COURT OF APPEALS CORONA, J.:



FACTS:
            The accused-appellant was under surveillance for four days by police operatives. On the fourth day, at about midnight, the police operatives conducted a buy-bust operation on the house of the accused. The buy-bust operation went successful and that the accused was found to have sold to the poseur-buyer(police operative) a 0.73 gram-Methamphetamine Hydrochloride (shabu), a regulated drug.

ISSUE:
Whether the trial court and the court of appeals overlooked certain material and undisputed facts in erroneously concluding that the alleged buy-bust operation conducted without a search warrant or warrant of arrest took place outside the residence of the petitioner.

HELD:
Well-settled is the rule that findings of trial courts which are factual in nature and which involve the credibility of witnesses are to be respected when no glaring errors, gross misapprehension of facts and speculative, arbitrary and unsupported conclusions can be gleaned from such findings. Such findings carry even more weight if they are affirmed by the Court of Appeals, as in the case at bar. The alleged flaws pointed out by appellant are not enough for us to reverse the factual findings of the courts a quo.
The police officers were clear and categorical in their narration of how the entrapment operation was conducted. SPO1 Inciong, acting as a poseur-buyer, was introduced by the informer to appellant in front of the latter’s apartment. Thereafter, appellant went inside his apartment and came back with two packets of shabu. Inciong handed to appellant six pieces of P100 bills treated with ultra-violet powder in exchange for one packet of shabu. Immediately after, Inciong gave the signal to the other policemen who then entered the compound and effected appellant’s arrest. Recovered from appellant was the other packet of shabu and the six pieces of marked money. The tests conducted on these pieces of evidence, appellant’s hands and right front pants-pocket showed that appellant was the same person who sold the drugs to police officer Inciong. There was strong evidence therefore, certainly beyond reasonable doubt, that appellant was engaged in drug-dealing.
The elements of the crime were duly proven. In the prosecution of the offense of illegal sale of prohibited drugs, what is material is the proof that the transaction or sale actually took place, coupled with the presentation in court of the corpus delicti as evidence.23
On the other hand, appellant insists he was framed up for possession of shabu after the search in his apartment produced no illegal drugs. Frame-up, a usual defense of those accused in drug-related cases, is viewed by the Court with disfavor since it is an allegation that can be made with ease. For this claim to prosper, the defense must adduce clear and convincing evidence to overcome the presumption that the arresting policemen performed their duties in a regular and proper manner.

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