People v. Campomanes
REITERATIONFacts
The Antecedents: The case involves the conviction of Edith Mendoza and Peter Campomanes for illegal sale of dangerous drugs under Section 5, Article II of Republic Act No. 9165. The prosecution alleged that on March 22, 2003, in Pasig City, the accused, conspiring together, sold one heat-sealed transparent plastic sachet containing 0.08 grams of white crystalline substance, later found to be methylamphetamine hydrochloride, to a police poseur-buyer, PO1 Allan Mapula. A separate charge for illegal possession of drug paraphernalia against Campomanes was not pursued due to his death. Procedural History: Following their arrest during a buy-bust operation, both accused were charged in two separate informations. The Regional Trial Court (RTC), Branch 70, Pasig City, convicted both Campomanes and Mendoza of illegal sale of dangerous drugs and Campomanes of illegal possession of drug paraphernalia. They appealed their conviction. However, Campomanes later passed away. The Court of Appeals affirmed the RTC's decision, finding no reason to overturn the conviction. This led to the present petition for review before the Supreme Court. The Petition: This case is before the Supreme Court on a petition for review under Rule 45 of the Rules of Court, assailing the decision of the Court of Appeals. The petitioner, Edith Mendoza, raises several issues, including whether the police officers followed the prescribed procedure in the initial custody of the seized drugs as per Section 21 of RA 9165, whether the decision of the lower court was in accordance with the latest jurisprudence, and whether the prosecution proved her guilt beyond reasonable doubt. Specifically, she argues that the testimonies of the police officers were inconsistent regarding who received the buy-bust money and that the chain of custody of the seized evidence was not properly established. The petition also questions the finding of conspiracy between her and co-accused Campomanes.
Issue(s)
Whether or not the police officers followed the prescribed procedure in the initial custody of the drugs seized and/or confiscated as provided under Section 21, Article II of R.A. No. 9165. Whether or not the questioned decision of the Court a quo is in accordance with the latest en banc jurisprudence. Whether or not the prosecution has proven the guilt of the accused with proof beyond reasonable doubt. Whether or not the trial court gravely erred in finding that the two accused-appellants conspired and confederated with one another in the commission of the crime charged. Whether or not the trial court gravely erred in finding accused-appellant Edith Mendoza guilty beyond reasonable doubt of violation of Section 5, Article II, R.A. No. 9165.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, upholding the conviction of Edith Mendoza for illegal sale of dangerous drugs under Section 5, Article II of Republic Act No. 9165. The Court found that the elements of the crime were established and that the prosecution sufficiently proved Mendoza's guilt beyond reasonable doubt. The Court also ruled that any alleged non-compliance with Section 21 of R.A. No. 9165 was not fatal to the prosecution's case, especially since the integrity and evidentiary value of the seized items were preserved and the issue was raised for the first time on appeal.
Ratio Decidendi
On the chain of custody and compliance with Section 21 of R.A. No. 9165: While acknowledging that the police operatives did not strictly comply with the inventory and photographing requirements under Section 21 of R.A. No. 9165, the Court held that such non-compliance is not fatal as long as the integrity and evidentiary value of the seized items are preserved. The Court noted that the seized sachet of shabu and the buy-bust money were immediately marked in the presence of the accused, turned over to the investigator, and then submitted to the crime laboratory for analysis. Crucially, the Court pointed out that the petitioner failed to challenge the custody, safekeeping, disposition, or preservation of the seized items before the RTC, raising the issue for the first time on appeal. The Court reiterated its ruling in People v. Sta. Maria that objections to evidence cannot be raised for the first time on appeal. On the credibility of witnesses and alleged inconsistencies: The Court found no material inconsistency or contradiction in the testimonies of PO1 Mapula and PO2 Laro that would overturn Mendoza's conviction. The alleged discrepancies cited by the petitioner were deemed minor and did not touch upon the central fact of the crime. The Court emphasized that the findings of the trial court on the credibility of witnesses, especially when affirmed by the Court of Appeals, are entitled to great respect, as these courts have the advantage of observing the witnesses' demeanor. On the guilt of the accused beyond reasonable doubt and the elements of illegal sale of dangerous drugs: The Court reiterated that a successful prosecution for illegal sale of dangerous drugs requires proof of the identities of the buyer and seller, the object and consideration of the sale, and the delivery of the thing sold and payment therefor. In this case, PO1 Mapula, the poseur-buyer, positively identified petitioner Edith Mendoza as the person who dealt with him and the informant during the buy-bust operation. Mendoza asked what they needed, accepted the marked ₱100.00 bill, and went inside the house, after which Campomanes emerged with the sachet of shabu. The substance was later confirmed to be shabu through laboratory examination. The Court found that all elements were clearly established, and the prosecution successfully proved the corpus delicti. On conspiracy: The Court sustained the finding of conspiracy between Campomanes and Mendoza. The actions of Mendoza in receiving the buy-bust money and facilitating the transaction, followed by Campomanes' delivery of the prohibited drug, demonstrated a common purpose and concerted action to commit the offense. The Court viewed their participation as a coordinated effort to sell illegal drugs, thus establishing conspiracy. On the guilt of the accused beyond reasonable doubt and the elements of illegal sale of dangerous drugs (reiterated): The Court reiterated that a successful prosecution for illegal sale of dangerous drugs requires proof of the identities of the buyer and seller, the object and consideration of the sale, and the delivery of the thing sold and payment therefor. In this case, PO1 Mapula, the poseur-buyer, positively identified petitioner Edith Mendoza as the person who dealt with him and the informant during the buy-bust operation. Mendoza asked what they needed, accepted the marked ₱100.00 bill, and went inside the house, after which Campomanes emerged with the sachet of shabu. The substance was later confirmed to be shabu through laboratory examination. The Court found that all elements were clearly established, and the prosecution successfully proved the corpus delicti.
Main Doctrine
The prosecution must establish the identity of the buyer and seller, the object and consideration of the sale, and the delivery of the thing sold and payment therefor. In illegal sale of shabu, proof of the transaction and presentation of the corpus delicti are material. Non-compliance with Section 21 of RA 9165 is not fatal if the integrity and evidentiary value of the seized items are preserved, and if the issue is not raised before the trial court.