G.R. No. 180511 ; July 28, 2008
People of the Philippines, Plaintiff-Appellee, vs. Marilyn Naquita y Cibulo, Accused-Appellant.

FACTS

On September 17, 2003, based on a tip from a confidential informant, a buy-bust team was formed in Caloocan City with PO1 Joel Cosme as the poseur-buyer. The team proceeded to Binangonan Street, Maypajo. The informant introduced PO1 Cosme to accused-appellant Marilyn Naquita as a buyer. Naquita asked how much he wanted, and Cosme replied “Kalahating bulto” worth three thousand pesos. Cosme handed over marked money, and Naquita gave him one plastic sachet. Upon receiving the sachet, Cosme gave the pre-arranged signal and arrested Naquita. PO1 Randy Llanderal then recovered two more plastic sachets from Naquita’s pocket. The seized items were marked and later confirmed by forensic examination to contain methylamphetamine hydrochloride.
At trial, Naquita denied the charges, claiming she was merely waiting for a ride when she was forcibly taken by men who demanded money and later framed her. She asserted that the prosecution failed to prove her guilt beyond reasonable doubt, specifically challenging the integrity of the seized drugs by pointing out alleged non-compliance with the chain of custody requirements under Section 21 of Republic Act No. 9165 .

ISSUE

Whether the prosecution successfully proved the guilt of the accused for illegal sale and possession of dangerous drugs beyond reasonable doubt, particularly in establishing the integrity and identity of the corpus delicti.

RULING

Yes. The Supreme Court affirmed the conviction. The Court held that all elements of illegal sale and illegal possession of dangerous drugs were proven. For the sale, the transaction where Naquita sold shabu to the poseur-buyer for marked money was clearly established. For possession, the recovery of two additional sachets from her person was duly testified to by the arresting officers. The Court ruled that non-compliance with Section 21’s witness requirements for the physical inventory does not automatically void the seizure or invalidate the evidence, provided the integrity and evidentiary value of the seized items are properly preserved. Here, the prosecution maintained an unbroken chain of custody. The buy-bust team immediately marked the seized sachets at the police station, and these same items were the ones submitted for laboratory examination and presented in court. The defense of frame-up was rejected for lack of clear and convincing evidence, as the testimonies of the police officers were accorded full faith and credit, their actions being presumed regular in the performance of official duty. The identity and integrity of the corpus delicti were thus safeguarded, proving guilt beyond reasonable doubt.