G.R. No. 148668 ; June 17, 2003
PEOPLE OF THE PHILIPPINES, Appellee, vs. TONY PEDRONAN y LIMMAYOG, Appellant.

FACTS

The prosecution alleged that based on a tip, a buy-bust operation was conducted against appellant Tony Pedronan at a restaurant in Baguio City. SPO2 Frederick Laoang acted as poseur-buyer, accompanied by a confidential informant. Appellant arrived, negotiated the sale of marijuana bricks, left to retrieve the drugs, and later returned with a green backpack containing 4.026 kilograms of marijuana. Upon inspection and seeing the contents, Laoang gave the pre-arranged signal, leading to appellant’s arrest. The seized items tested positive for marijuana. The Regional Trial Court convicted appellant of violating the Dangerous Drugs Act and sentenced him to reclusion perpetua and a fine.
Appellant presented a different account, claiming he was at the restaurant for dinner before a planned trip to Manila when policemen he knew invited him to their office. He alleged that upon boarding their vehicle, they took money from his wallet. At the office, after finding no drugs on him, a confrontation ensued where he was mauled. He denied selling drugs, possessing the green backpack, or knowing the informant. He insisted the backpack was only produced later when the police prepared their report.

ISSUE

Whether the prosecution proved appellant’s guilt for the illegal sale of marijuana beyond reasonable doubt.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED appellant. The Court emphasized that in drug cases, the prosecution must establish the identity of the buyer and seller, the object, and the consideration, alongside the crucial preservation of the chain of custody of the seized drugs. The Court found the police officers’ conduct of the buy-bust operation highly irregular and contrary to standard procedure, creating reasonable doubt. The poseur-buyer admitted he never actually gave the marked money to appellant because the drugs delivered exceeded the agreed quantity, a deviation from the typical consummated sale transaction. Furthermore, the team failed to immediately mark the seized items at the place of arrest. The marking was done later at the police station, with no explanation for the delay, breaking the chain of custody. This failure to follow procedure compromised the integrity of the evidence, as it became uncertain whether the marijuana presented in court was the same substance allegedly seized from appellant. The presumption of regularity in the performance of official duty cannot prevail over the constitutional presumption of innocence and the prosecution’s burden to prove guilt beyond reasonable doubt, which was not met due to these procedural lapses.