G.R. No. 252857 , March 18, 2021
People of the Philippines, Plaintiff-Appellee, vs. Karlo Guarin y Bañaga, Accused-Appellant.

FACTS

On March 23, 2015, a buy-bust operation was conducted against Karlo Guarin y Bañaga (appellant) in Camiling, Tarlac. PO1 Abel Corpuz acted as the poseur-buyer and purchased one plastic sachet of suspected shabu from the appellant for a marked P500 bill. Upon the pre-arranged signal, the backup team arrested the appellant. A search incidental to arrest yielded two more plastic sachets from the appellant’s person. At the place of arrest, PO1 Corpuz immediately marked the seized sachets: “AC” (the sold item) and “AC-1” and “AC-2” (the items found in possession). The inventory and photographing were done in the presence of the appellant, a Barangay Kagawad, and a media representative. The items were then brought to the police station. That same afternoon, PO1 Corpuz personally delivered the seized items to the Tarlac Crime Laboratory. Forensic Chemist PSI Angelito S. Angel received the items, conducted an examination, and found the contents of all three sachets positive for methamphetamine hydrochloride. He then resealed the sachets, placed them in a sealed brown envelope marked “D-092-15 ASA,” and retained custody. The appellant was charged with Illegal Sale and Illegal Possession of Dangerous Drugs under Sections 5 and 11, Article II of Republic Act No. 9165 . The appellant denied the charges, claiming he was framed. The Regional Trial Court convicted him, and the Court of Appeals affirmed the conviction. The appellant appealed to the Supreme Court, arguing the prosecution failed to establish the chain of custody and integrity of the seized drugs.

ISSUE

Whether the Court of Appeals erred in affirming the conviction despite the alleged failure of the prosecution to establish the chain of custody and integrity of the seized drugs.

RULING

The Supreme Court dismissed the appeal and affirmed the conviction. The Court held that the prosecution successfully established an unbroken chain of custody and preserved the integrity and evidentiary value of the seized drugs. All links in the chain were duly accounted for: (1) The seizure and marking were done immediately at the place of arrest in the presence of the appellant and required witnesses. (2) The items were then turned over to the investigating officer, PO1 Corpuz, who maintained custody until their submission to the crime laboratory. (3) PO1 Corpuz personally delivered the items to the forensic chemist, PSI Angel, who took custody, conducted the examination, and resealed the items in a tamper-evident envelope. (4) The forensic chemist testified on the handling and examination process. (5) The items were properly identified in court. The Court found that the procedural requirements under Section 21 of R.A. No. 9165 , as amended by R.A. No. 10640 , were substantially complied with, and the integrity of the corpus delicti was preserved. The appellant’s defenses of denial and frame-up were deemed weak and unsubstantiated. The non-presentation of every individual who had interim custody (e.g., evidence custodian) was not fatal, as the prosecution has discretion in presenting witnesses, and the identity and integrity of the evidence were sufficiently proven.