Complaint( Drug Case).docx

Proposal for Admissions 1. The identity of the accused Archilles Natividad Dupaya. 2. That on August 4, 2018 around 5:00 o’clock in the morning, confidential informant proceeded to Tuguegarao City Police Station and informed SPO3 Ronald Felipe that the respondent is selling illegal drugs in Tuguegarao City and was looking for prospective buyer. 3. That SPO3 Felipe instructed the CI to call up “Chic” and inform him that (CI) has a friend who wants to buy shabu amounting to 1,000 pesos. During the phone conversations Chic instructed the CI to accompany his friend to meet him up at his boarding house at around 7:00 o’clock in the evening of August 4, 2018. 4. That around 5:00 o’clock in the afternoon of August 4, 2018, SPO3 Felipe formed a team to conduct buy-bust operation against Chic. PO2 Vicente Lacambra Sibel was designated as the poseur buyer while PO3 Jaypy Cuartos and PO2 Calixto Melad, Jr. as the arresting officers. 5. That after the briefing, coordination was made to the PDEA Regional Office 2 in preparation for buy-bust operation to be conducted against Chic. 6. Upon arrival at the place of transaction to conduct buy-bust operation against “Chic”, the CI and PO2 Vicente Sibal directly at room 7 located at the second floor while the members of the team positioned themselves at the groundfloor. Once inside the room at around 7:00 o’clock in the evening of August 4, 2018, the CI introduced PO2 Vicente Lacambra as the buyer of the shabu. A brief transaction was ensued between PO2 Vicente and Chic, Chic handed 1 piece heat sealed transparent plastic sachet containing white crystalline substance and in return PO2 Vicente handed him the buy-bust money. 7. PO2 Vicente then immediately dialled the cellphone of PO3 Cuarteros to let his cellphone ring as a sign that the act of selling shabu has been consummated. After five seconds, PO3 Cuarteros , PO2 Melad and the rest of the team arrived and introduced themselves as police officers. PO3 Cuarteros immediately arrested “Chic” after informing the reason of his arrest and his right under Miranda Doctrine while PO2 Melad on the otherhand confiscated from his direct possession and control the color black pouch containing white crystalline substance and one unit color white Samsung cellphone. 8.The inventory and marking of the pieces of evidence against the suspect identified as Archilles Natividad Dupaya Alias “Chic”, was made at the place of transaction in his presence witnessed by Mr. Ferdinand Gangan from Department of Justice, Brgy. Captain Lucas Ballad of Tang, Tuguegarao City and Brgy. Captain Nestor Bucan of Belgain East, Tuguegarao City, wherein PO2 Vicente marked the buy-bust staff with VSL, date of 08-04-18 and his signature written on a masking tape while PO2 Melad marked the 1 piece heat sealed transparent plastic sachet containing white crystalline substance with CCA, date 08-04-18 and his signature written on a masking tape; the color white Samsung cellphone with CCA-1, date of 08-04-18 and his signature written on a masking tape; and the black pouch with CCA-2 date 08-04-18 and his signature written on a masking tape. The photographs during the conduct of inventory were taken by PO2 Bryan Escobar.

9. The suspect and the pieces of evidence were brought to the COMPAC Don Domingo, Tuguegarao City Police Station for documentation and proper disposition. 10. That PO2 Melad and PO2 Vicente brought the suspect and the pieces of evidence at the Philippine Drug Enforcement Regional Office 2 for drug test and laboratory examination, respectively.

DOCUMENTARY EVIDENCES 1. Exhibit A- the affidavit of poseur buyer, PO2 Vicente Lacambra, dated August 5, 2018 in Tuguegarao City, Cagayan. Purpose: 2. Exhibit B- Joint affidavit of arrest of PO3 Jaypy Cuarteros y Iringan and PO2 Calixto Melad, Jr. dated August 5, 2015 in Tuguegarao City, Cagayan Purpose: 3. Exhibit C- Excerpt of the Police Blotter dated August 4, 2018 certified by PO2 Sherwin Flaviano Purpose: To prove that an buy-bust operation.

operatives were dispatched to conduct anti-illegal drug

That PO2 Sherwin Flaviano was dispatched to conduct inventory after the drug buy-bust operation happened at John Rick boarding house. 4. Exhibit D- Excerpt from the police Blotter of Tuguegarao City Police Station dated August 4, 2018 certified by PO2 Sherwin Flaviano Purpose: To prove that the buy-bust team returned to the City Police Station with Suspect Archilles Natividad Dupaya. 5.Exhibit E- Coordination Form of the buy-bust. 6. Exhibit F- Pre-operation Report dated August 4, 2018 7. Exhibit G- Receipt and inventory of confiscated items dated August 4, 2018 Purpose: To prove the evidence of 1 piece heat sealed sachet containing white crystalline substance. 8. Exhibit H- Receipt and Inventory of confiscated items dated August 4, 2018. Purpose: To show the existence of one unit color white Samsung touch pad cellphone. 9. Exhibit I- Copy of Request for Laboratory Examination 10. Exhibit J- Copy of the Request for Drug Examination 11. Exhibit K- Chain of Custody 12. Exhibit L- Acknowledgement receipt from the PDEA 13. Exhibit M- Chemistry Report No. PDEA-DDO2-18-228 of theLaboratory Examination 14. Exhibit N- Chemistry Report for the drug test examination conducted to Archilles Dupaya 15. Exhibit O- Chain of Custody

Testimonial Evidence 1. PO2 Calixto Melad, Jr. PNP Tuguegarao City Police Station 2. PO3 Jaypy Cuarteros 3. PO2 Vicente S. Lacambra 4. Jomar L. Concepcion, Chemist, PDEA Regional Crime Laboratory Office No. 02, Camp Addures, Tuguegarao City and others.