G.R. No. 240664. March 11, 2019
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. JONATHAN MAYLON Y ALVERO ALIAS “JUN PUKE” AND ARNEL ESTRADA Y GLORIAN, ACCUSED-APPELLANTS.

FACTS

This case stemmed from a buy-bust operation conducted by the Station Anti-Illegal Drugs Special Operation Task Group of Marikina City on August 10, 2014. The prosecution alleged that accused-appellant Jonathan Maylon sold one plastic sachet of shabu to PO3 Junar Olveda, who acted as poseur-buyer. During the operation, PO3 Olveda also witnessed accused-appellant Arnel Estrada receive a sachet from Maylon. Upon arrest, seven more sachets were recovered from Maylon and one from Estrada. The seized items were marked at the scene, followed by an inventory at the police station conducted in the presence of a barangay kagawad, a councilor, and a media representative. Forensic examination confirmed the contents were methamphetamine hydrochloride.
In their defense, accused-appellants denied the allegations, claiming they were arbitrarily arrested. Estrada asserted he was taken from a store near his house without explanation, after which the police proceeded to arrest the sleeping Maylon. They alleged that the drugs were merely presented to them at the barangay hall and that the charges were fabricated.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellants for violations of Sections 5 and 11, Article II of Republic Act No. 9165, despite alleged irregularities in the chain of custody of the seized drugs.

RULING

The Supreme Court denied the appeal and affirmed the convictions. The Court held that all elements of illegal sale and illegal possession of dangerous drugs were proven beyond reasonable doubt. For illegal sale, the transaction between Maylon and the poseur-buyer was clearly established. For illegal possession, both accused were found in conscious possession of shabu without legal authority. The trial court’s assessment of witness credibility, which favored the prosecution’s version, is accorded great respect.
Crucially, the Court ruled that the chain of custody over the seized items was preserved. While the marking was done immediately at the place of arrest, the inventory and photography were conducted at the police station in the presence of the required witnesses: a barangay kagawad, an elected official, and a media representative. This procedure constitutes substantial compliance with Section 21 of RA 9165. The law recognizes that marking at the nearest police station is acceptable when immediate marking at the arrest site is not practicable. The integrity and evidentiary value of the corpus delicti were thus maintained from seizure, to inventory, to laboratory examination, and finally to presentation in court. The defense of frame-up and denial, being uncorroborated, cannot prevail over the positive testimonies of the police officers and the established chain of custody.