G.R. No. 174097; July 21, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. SONNY PADUA y REYES, Accused-Appellant.

FACTS

Accused-appellant Sonny Padua y Reyes was charged with illegal sale and possession of methamphetamine hydrochloride or shabu under Republic Act No. 9165. The prosecution alleged that on August 18, 2002, a buy-bust operation was conducted in Taguig City. PO2 Dante Aguilar acted as the poseur-buyer and handed marked money to Padua in exchange for one plastic sachet of shabu. Upon the pre-arranged signal, Padua was arrested. A subsequent search yielded the buy-bust money from his left pocket and four more sachets of shabu from his right pocket. The seized items were submitted for laboratory examination, which confirmed the presence of methamphetamine hydrochloride.
The defense presented a different version, claiming Padua was merely a bystander near a store when he was forcibly taken by individuals who later turned out to be police officers. He alleged he was framed, and the drugs were planted. The Regional Trial Court found him guilty, a decision affirmed by the Court of Appeals. Padua appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt and failed to establish the chain of custody of the seized drugs.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for violations of Sections 5 and 11, Article II of R.A. No. 9165.

RULING

The Supreme Court affirmed the conviction. The Court found the prosecution successfully established all elements of illegal sale and illegal possession of dangerous drugs. PO2 Aguilar’s testimony credibly detailed the buy-bust operation: the offer to purchase, the payment, and the delivery of the illicit drug. The recovery of the marked money and additional sachets from Padua’s person confirmed illegal possession. The defense of frame-up was rejected for being unsubstantiated and a common allegation easily fabricated.
Regarding the chain of custody, the Court ruled that while the ideal procedure under Section 21 of R.A. No. 9165 was not meticulously followed—such as the lack of immediate physical inventory and photographing at the place of seizure—this did not automatically invalidate the seizure. The integrity and evidentiary value of the seized items were preserved. PO2 Aguilar testified to having marked the seized items and turning them over to the investigator, who then submitted them to the crime laboratory. The forensic chemist confirmed the items tested positive for shabu. The prosecution thus provided a sufficient account of the handling of the evidence from seizure to laboratory examination, overcoming any presumption of tampering. Minor procedural lapses, absent proof of bad faith, do not negate a finding of guilt.