People v. Gutierrez
REITERATIONFacts
The Antecedents: A confidential informant reported that accused Melody Gutierrez y Lauriada and an alias Toto were selling illegal drugs on Adora Street, Barangay Tejeros, Makati City. Police Officer 1 (PO1) Jaime Orante, Jr. verified the accused's name on the Makati Drug Abuse Council (MADAC) watch list. A buy-bust operation was organized, with PO1 Orante as the poseur-buyer. During the operation, PO1 Orante handed marked money to the accused, who then gave him a plastic container and a plastic sachet containing a white crystalline substance, identified as methylamphetamine hydrochloride (shabu). The accused was arrested, and the confiscated sachets were found to contain shabu. The accused was charged with violations of Republic Act No. 9165 (RA 9165) for selling and possessing illegal drugs. Procedural History: The Regional Trial Court (RTC) of Makati City found the accused guilty beyond reasonable doubt for both offenses and sentenced her to life imprisonment and a fine of ₱500,000.00 for the sale, and an indeterminate sentence of 14 years, 8 months, and 1 day as minimum for possession, with a fine of ₱300,000.00. The accused appealed to the Court of Appeals (CA), arguing insufficient corroboration and failure to present the informant and forensic chemist. The CA affirmed the RTC decision in toto. The accused then appealed to the Supreme Court. The Petition: The accused appealed to the Supreme Court, assailing the CA's decision affirming her conviction. The parties manifested that they would no longer file supplemental briefs.
Issue(s)
Whether the guilt of the accused for illegal sale and possession of dangerous drugs was proven beyond reasonable doubt. Whether the indeterminate sentence imposed for illegal possession of dangerous drugs was correctly determined.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals with modification. The conviction for illegal sale and possession of dangerous drugs was upheld. However, the indeterminate sentence for the charge of illegal possession of dangerous drugs in Criminal Case No. 07-287 was modified to comply with the Indeterminate Sentence Law and the penalties prescribed by RA 9165.
Ratio Decidendi
On the guilt for illegal sale and possession of dangerous drugs: The Court found no reason to disturb the factual findings of the trial court, as affirmed by the Court of Appeals. The prosecution successfully proved the elements of the illegal sale and possession of shabu through the testimony of PO1 Orante, who acted as the poseur-buyer. The Court emphasized that what is material is proof that the transaction took place, coupled with the presentation of the corpus delicti, which was established by the testimony of PO1 Orante. The consummation of the sale was corroborated by MADAC Operative Joebert Dela Peña. The Court also found that the chain of custody of the seized illegal drugs was sufficiently established, despite the absence of the forensic chemist's testimony, as the defense admitted the authenticity of the Physical Science Report during pre-trial. The accused's defense of denial and claim of abduction was not given credence. On the indeterminate sentence for illegal possession: The Court noted an error in the penalty imposed by the trial court for illegal possession of dangerous drugs (Criminal Case No. 07-287). The trial court sentenced the accused to an indeterminate term of 14 years, 8 months, and 1 day as minimum, without providing for a maximum penalty. Under the Indeterminate Sentence Law, the maximum term shall not exceed the maximum fixed by law, and the minimum shall not be less than the minimum term prescribed. Article II, Section 11 of RA 9165 provides for penalties based on the quantity of dangerous drugs. For quantities less than five grams of methamphetamine hydrochloride, the penalty is imprisonment of 12 years and 1 day to 20 years and a fine of ₱300,000.00 to ₱400,000.00. The Court modified the sentence to an indeterminate sentence of 12 years and 1 day, as minimum, to 14 years, as maximum, considering the absence of aggravating circumstances and the prescribed penalty range.
Main Doctrine
The Court affirmed the conviction for illegal sale and possession of dangerous drugs, modifying the indeterminate sentence for possession to comply with the Indeterminate Sentence Law and the penalties prescribed by Republic Act No. 9165.