Primary Holding

The Supreme Court affirmed the Court of Appeals' decision, which upheld the Regional Trial Court's conviction of Joey Meneses y Cano for illegal sale of dangerous drugs, finding him guilty beyond reasonable doubt of violating Section 5, Article II of R.A. No. 9165.

Background

Joey Meneses was apprehended in a buy-bust operation conducted by police officers after a confidential informant reported his drug dealing activities. The operation stemmed from an initial transaction where Meneses sold marijuana to an undercover police officer. Subsequently, a planned buy-bust operation led to his arrest for selling both marijuana and shabu.

Facts

• 1. A confidential informant reported drug dealing activities by a driver of an Elf Truck.
• 2. PO2 Dela Cruz, posing as a buyer, initially purchased marijuana from Meneses on November 28, 2013.
• 3. On December 11, 2013, a buy-bust operation was planned after the informant indicated Meneses was looking for the poseur-buyer.
• 4. Meneses sold one brick of marijuana and one sachet of shabu to PO2 Dela Cruz at CB Mall Public Transport Terminal.
• 5. Meneses was arrested after the transaction, along with Balila. Limson was initially arrested but later acquitted by demurrer to evidence.
• 6. Marking, inventory, and photography of the seized drugs were conducted at the scene with required witnesses present.
• 7. Laboratory examination confirmed the seized items were marijuana and shabu.
• 8. Meneses claimed he was framed and denied selling drugs, stating he was merely checking his truck tires when arrested by armed men.

Arguments of the Petitioners

• 1. Meneses argued that the prosecution failed to prove the existence of an agreed consideration for the illegal sale of drugs.
• 2. He contended there was no meeting of minds regarding the price of the drugs with the poseur-buyer.
• 3. Meneses raised the defense of frame-up and denial, claiming he was merely present at the location to check his truck tires and was wrongly arrested.

Arguments of the Respondents

• 1. The prosecution argued that the buy-bust operation was valid and properly conducted.
• 2. They presented testimonies of police officers who positively identified Meneses as the seller.
• 3. The prosecution asserted that the delivery of drugs and acceptance of payment, regardless of a pre-agreed price, consummated the illegal sale.
• 4. They emphasized the chain of custody was properly observed and the seized drugs tested positive.
• 5. The prosecution countered that Meneses' defenses of denial and frame-up were weak and unsubstantiated.

Issues

• 1. Whether the prosecution sufficiently proved the illegal sale of dangerous drugs beyond reasonable doubt.
• 2. Whether the lack of a pre-agreed price negates the consummation of the illegal sale.
• 3. Whether Meneses’ defense of frame-up and denial should be given credence.
• 4. Whether the buy-bust operation and chain of custody of evidence were valid.

Ruling

• 1. The Supreme Court ruled in favor of the prosecution, finding that all elements of illegal sale of dangerous drugs were proven.
• 2. The Court held that the delivery of the drugs and the acceptance of buy-bust money, even without a pre-established price, constituted a consummated sale because Meneses affirmed the price by accepting payment after delivery.
• 3. The Court dismissed Meneses' defenses of denial and frame-up as weak and self-serving, failing to overcome the positive testimonies of the prosecution witnesses and the presumption of regularity in the performance of official duties by law enforcement.
• 4. The Court affirmed the validity of the buy-bust operation and found that the chain of custody was properly maintained, preserving the integrity and identity of the seized drugs.

Doctrines

• 1. Corpus Delicti: In drug cases, the corpus delicti is the dangerous drug itself, which must be presented as evidence and its identity must be clearly established. The Court found the corpus delicti was proven by the seized drugs and their positive identification.
• 2. Buy-Bust Operation: A valid entrapment technique to catch offenders in flagrante delicto of drug offenses. The Court found the buy-bust operation to be valid as it followed established procedures.
• 3. Chain of Custody: The process of tracking seized items to ensure their integrity and identity from seizure to presentation in court. The Court determined the chain of custody was properly maintained.
• 4. Presumption of Regularity in the Performance of Official Duty: Law enforcement officers are presumed to have acted regularly in the performance of their duties, unless there is clear and convincing evidence to the contrary. Meneses failed to overcome this presumption.
• 5. Defense of Denial and Frame-up: These defenses are viewed with disfavor in drug cases, as they are easily fabricated and often used. The Court found Meneses' defenses to be unsubstantiated and weak.

Key Excerpts

• 1. "The commission of illegal sale merely requires the consummation of the selling transaction, which happens the moment the buyer receives the drug from the seller."
• 2. "In the illegal sale of dangerous drugs, the most important part of the buy-bust operation is the actual exchange of the buy-bust money and the subject drug."
• 3. "The defenses of denial, frame-up and extortion, like alibi, have been invariably viewed by the courts with disfavor for they can easily be concocted and are common and standard defense ploys in most cases involving violation of the Dangerous Drugs Act."

Precedents Cited

• 1. People v. Endaya: Cited to emphasize that consummation of illegal sale occurs upon delivery of drugs and acceptance of payment, regardless of pre-agreed price.
• 2. People v. Ismael: N/A (General citation, no specific context provided in the text).
• 3. People v. Amaro: N/A (General citation, no specific context provided in the text).
• 4. People of the Philippines v. Almaser Jodan y Amla: Cited for the importance of clearly establishing the identity of the dangerous drug as part of the corpus delicti.
• 5. People v. Tamaño, et al.: N/A (General citation, no specific context provided in the text).

Statutory and Constitutional Provisions

• 1. Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002): The law violated by Meneses, concerning the illegal sale of dangerous drugs.
• 2. Section 21, Article II of R.A. No. 9165 and its Implementing Rules and Regulations: Pertains to the procedure for the custody and handling of seized drugs, which the Court found to have been complied with.
• 3. Civil Code: Mentioned as not applicable in determining the validity of an illegal drug sale due to its unlawful nature.