G.R. No. 182790 , April 24, 2009
People of the Philippines, Appellee, vs. Cesar Cantalejo y Manlangit, Appellant.

FACTS

An Information was filed against appellant Cesar Cantalejo for violating Section 5 of R.A. No. 9165 (Comprehensive Dangerous Drugs Act of 2002). The prosecution’s version, based on testimonies of PO2 Paul Acosta and PO1 Romualdo Cruda, was that on January 20, 2004, after a report from police assets, a buy-bust team was formed with PO2 Acosta as poseur-buyer. Acosta, using a marked ₱500 bill, bought a plastic sachet of shabu from appellant at his residence. Upon Acosta’s signal, the team arrested appellant, recovered the marked money, and seized the sachet, which was later confirmed to contain shabu. The defense, comprising appellant, his wife Virginia, and neighbor Nomeriano Belen, Jr., presented a different account. They testified that police officers forcibly entered their house without a warrant between 1:00 and 2:00 a.m., searched for shabu, found none, but still arrested appellant. They alleged the buy-bust was a frame-up. The Regional Trial Court convicted appellant, sentencing him to life imprisonment and a fine. The Court of Appeals affirmed the conviction. Appellant appealed to the Supreme Court, adopting his appellate brief.

ISSUE

Whether the prosecution proved beyond reasonable doubt that appellant is guilty of illegal sale of dangerous drugs.

RULING

The Supreme Court ruled in favor of the appellant and reversed the lower courts’ decisions. The prosecution failed to prove guilt beyond reasonable doubt. Key deficiencies were identified: 1) The prosecution relied heavily on the testimonies of two police officers without presenting other team members or rebuttal evidence to counter the defense’s claim of frame-up and unlawful search, creating doubt about the occurrence of the buy-bust operation. 2) The identity of the corpus delicti (the dangerous drug) was not sufficiently established. The testimonies of PO2 Acosta and PO1 Cruda were unclear and did not definitively show compliance with the custody and disposition procedures under Section 21 of R.A. No. 9165 , specifically the requirements for physical inventory and photographing of seized items in the presence of required witnesses. The police offered no explanation for this non-compliance. This failure negated the presumption of regularity in the performance of official duties and raised doubts about the origins of the seized drug. Consequently, the constitutional presumption of innocence prevailed, warranting acquittal.