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PEOPLE v. REYNALDO CAPALAD Y ESTO

This case has been cited 8 times or more.

2014-04-07
VILLARAMA, JR., J.
With the unbroken chain of custody duly established by the prosecution evidence, the CA did not err in giving the same full credence in contrast to the denial by appellant who failed to substantiate his allegation of frame-up and extortion. Frame-up, like alibi, is generally viewed with caution by the Court because it is easy to contrive and difficult to disprove. It is a common and standard line of defense in prosecutions of violations of the Dangerous Drugs Act.[37]  To substantiate such defense, the evidence must be clear and convincing and should show that the members of the buy-bust team were inspired by any improper motive or were not properly performing their duty.  Otherwise, the police officers' testimonies on the operation deserve full faith and credit.[38]  No such evidence was presented by appellant in this case. The CA even quoted in part the decision of the RTC which highlighted the irreconcilable inconsistencies in the testimonies of defense witnesses on what transpired during the buy-bust operation.
2013-06-17
DEL CASTILLO, J.
In People v. Capalad,[33] this Court held thus: Charges of extortion and frame-up are frequently made in this jurisdiction. Courts are, thus, cautious in dealing with such accusations, which are quite difficult to prove in light of the presumption of regularity in the performance of the police officers' duties. To substantiate such defense, which can be easily concocted, the evidence must be clear and convincing and should show that the members of the buy-bust team were inspired by any improper motive or were not properly performing their duty. Otherwise, the police officers' testimonies on the operation deserve full faith and credit.
2013-02-06
LEONARDO-DE CASTRO, J.
There is little credence in Elizabeth's assertion that she and Linda were mere victims of a frame-up.  As the Court declared in People v. Capalad[19]: Charges of extortion and frame-up are frequently made in this jurisdiction. Courts are, thus, cautious in dealing with such accusations, which are quite difficult to prove in light of the presumption of regularity in the performance of the police officers' duties. To substantiate such defense, which can be easily concocted, the evidence must be clear and convincing and should show that the members of the buy-bust team were inspired by any improper motive or were not properly performing their duty. Otherwise, the police officers' testimonies on the operation deserve full faith and credit. (Citations omitted.)
2012-10-10
LEONARDO-DE CASTRO, J.
The Court further pronounced in People v. Capalad[33] that: Charges of extortion and frame-up are frequently made in this jurisdiction. Courts are, thus, cautious in dealing with such accusations, which are quite difficult to prove in light of the presumption of regularity in the performance of the police officers' duties. To substantiate such defense, which can be easily concocted, the evidence must be clear and convincing and should show that the members of the buy-bust team were inspired by any improper motive or were not properly performing their duty.  Otherwise, the police officers' testimonies on the operation deserve full faith and credit. (Citations omitted.)
2011-12-14
LEONARDO-DE CASTRO, J.
Charges of extortion and frame-up are frequently made in this jurisdiction.  Courts are, thus, cautious in dealing with such accusations, which are quite difficult to prove in light of the presumption of regularity in the performance of the police officers' duties.  To substantiate such defense, which can be easily concocted, the evidence must be clear and convincing and should show that the members of the buy-bust team were inspired by any improper motive or were not properly performing their duty. Otherwise, the police officers' testimonies on the operation deserve full faith and credit.[22]
2011-06-22
LEONARDO-DE CASTRO, J.
As we have time and again held, the defense of denial or frame-up, like alibi, has been invariably viewed with disfavor for it can easily be concocted and is a common defense in most prosecutions for violation of the Dangerous Drugs Act. [23] Charges of extortion and frame-up are frequently made in this jurisdiction.  Courts are, thus, cautious in dealing with such accusations, which are quite difficult to prove in light of the presumption of regularity in the performance of the police officers' duties.  To substantiate such defense, which can be easily concocted, the evidence must be clear and convincing and should show that the members of the buy-bust team were inspired by any improper motive or were not properly performing their duty. Otherwise, the police officers' testimonies on the operation deserve full faith and credit. [24]
2009-10-27
CHICO-NAZARIO, J.
In prosecutions involving the illegal sale of drugs, what is material is proof that the transaction or sale actually took place, coupled with the presentation in court of the prohibited or regulated drug as evidence.[21] For conviction of the crime of illegal sale of prohibited or regulated drugs, the following elements must concur: (1) the identities of the buyer and the seller, the object, and the consideration; and (2) the delivery of the thing sold and the payment for it.[22] The testimonial and documentary pieces of evidence adduced by the prosecution in support of its case against accused-appellant establish the presence of these elements.
2009-10-27
CHICO-NAZARIO, J.
Accused-appellant failed to adduce evidence to substantiate her claim of irregularity in the performance of duty on the part of the police officers. This bare allegation of irregularity in the performance of duty remained self-serving and bereft of any supporting evidence.[33] Neither was any ill motive imputed on the part of the police officers, thus failing to buttress the defense's claim of frame-up. Against the positive testimonies of the prosecution witnesses, accused-appellant's plain denial of the offenses charged, unsubstantiated by any credible and convincing evidence, must simply fail.[34] This Court realizes the disastrous consequences on the enforcement of law and order, not to mention the well being of society, if the courts accept in every instance this form of defense, which can be so easily fabricated. It is precisely for this reason that the legal presumption that official duty has been regularly performed exists. If she were truly aggrieved, it is quite surprising why accused-appellant did not even attempt to file a criminal or an administrative complaint, e.g., for planting drugs, against the arresting officers. Such inaction runs counter to the normal human conduct and behavior of one who feels truly aggrieved by the act complained of.[35] The totality of the evidence points to the fact of the sale of the prohibited drug, with the prosecution witnesses clearly identifying accused-appellant as the offender.