REPUBLIC OF THE PHILIPPINES OFFICE OF THE PROSECUTOR BAGUIO CITY

SPO2 CLARIBEN B. PAREL, Complainant, - versus ROSHENDY VILLANUEVA, Respondent. x----------------------x

I.S. No. 645878 For: Violation of R. A. 9165, Art. II, Sec. 5

COMPLAINT-AFFIDAVIT I, SPO2 Clariben Parel, of legal age and a resident of 113 Upper General Luna Road, Baguio City, and a PNP member of Baguio City Police Station 5, Baguio City, Benguet assigned to PAID-SOTG, Baguio City Police Office and Anti-Drug Task Group/ Local PDEA, after having been duly sworn to in accordance with law, do hereby depose and state: That after conducting a weeklong surveillance against the suspected drug pusher within our Area of Responsibility, our Group came to know that a certain Roshendy Villanueva is engaged in the illegal sale of shabu;
1.

That at around 3:15 in the afternoon of December 4, 2011, PSUPT BENJAMIN ALDET, Chief of Police of Baguio City Police Station, conducted pre-operation conference to conduct a buy-bust operation against the suspect designating PO3 Miguel Corvite to act as poseur-buyer and designating the undersigned and PO3 Bevann Z. Cruz to act as back-up, after which PSUPT Aldet handed to the undersigned two (2) pieces of One Hundred Peso Bill with serial numbers Z679111 and SJ441842 as the buy-bust money, and after which our team proceeded to the residence of the suspect at No. 31 Purok 1, Barangay Lower Dagsian, Baguio City, Benguet, wherein she was making her business while our back-up team followed secretly the poseur-buyer and positioned ourselves strategically in order to observe the actual transaction between the suspect and the poseur-buyer;
2.

That at about 3:45 in the afternoon of the same date, we saw our poseur-buyer having conversation with the suspect, and the suspect handed something to our poseur-buyer that led him to raise up his right hand as the agreed pre-arranged signal to rush up to the scene and arrest the suspect;
3.

That we immediately entered the premises owned by the suspect to arrest her and the undersigned was able to recover the marked money used in the entrapment bearing serial numbers Z679111 and SJ441842 and three (3) pieces of small heat-sealed transparent plastic sachet containing white crystalline substance suspected to be shabu weighing more or less 0.1 gram each including plastic sachet from the direct possession, custody and control of Roshendy Villanueva;
4.

5. That upon arrest, the undersigned apprised the suspect of her constitutional rights; That the three (3) pieces of small heat-sealed transparent plastic sachet containing white crystalline substance suspected to be shabu weighing more or less 0.1 gram each were marked as MDC-1, MDC-2, and MDC-3 respectively;
6.

7. That the marked money consisting of two (2) One Hundred Peso bills were also marked as MDC-4 and MDC-5; That the operating troop, headed by the undersigned, which had initial custody and control of the drugs and marked money, immediately after seizure and confiscation, made a physical inventory and took photographs of the same in the presence of the accused Roshendy Villanueva, a representative from the media, ROWEE F. DAMASEN, and a representative of the Department of Justice, ATTY. ROXANNE V. PAGLINGAYEN, and Barangay Captain ALEX S. GUBING, and the same persons signed the copies of the inventory and were given copies thereof;
8.

That at about 5:00 in the afternoon of the same date, the shabu and marked money seized, together with the suspect arrested and the operating troop, were taken to the Baguio City Police Station 5, aboard the police car with plate number ACY 592;
9.

That at about 5:15 PM of the same date, the team and the suspect arrived at the Baguio City Police Station 5. The suspect, as well as the shabu and marked money, was turned over by the undersigned to the Investigator, PO2 Justin R. Azurin, to undergo police booking procedure, which included the taking of mug shots and fingerprints, and the recording of the marked money and the three (3) pieces of small heat-sealed transparent plastic sachet containing white crystalline substance suspected to be shabu in the police booking sheet;
10.

That at about 5:45 in the afternoon of the same date, the said Villanueva was detained at the Baguio City Police Station 5 to undergo custodial investigation, while the shabu, was turned over by PO2 Azurin to SPO4 Paul Reyes who brought the same to the Regional Crime Laboratory Office-Cordillera Administrative Region, Camp Bado Dangwa, La Trinidad, Benguet;
11.

That the three (3) pieces of small heat-sealed transparent plastic sachet containing white crystalline substance suspected to be shabu were received by PO1 ALBIE MAY A. LIYAD, RMT, the Forensic Analyst at the PDEA Forensic Laboratory at 6:30 in the evening of the same date;
12.

That the findings reveal that the result of the qualitative examination conducted by the undersigned on the above-stated specimens (A thru C) gave POSITIVE result to the test for the presence of Methamphetamine Hydrochloride (shabu), a dangerous drug;
13.

That I am executing this sworn statement for the purpose of charging the respondent with having violated Section 5, Article II of R.A No. 9165.
14.

City of Baguio, Philippines. December 7, 2011.

_______________________________________ CLARIBEN B. PAREL Complainant

SUBSCRIBED AND SWORN to before me this 7th day of December 2011 at Baguio City, Benguet, Philippines, the affiant exhibiting his CTC. No. 75977658 issued at the City of Baguio on January 8, 2011 and his Drivers License No. N29750378 issued by the Land Transportation Office on July 16, 2010.

______________________________________ MERCEDES G. ARTICONA City Prosecutor