G.R. No. 174481 , February 10, 2016
The People of the Philippines, Plaintiff-Appellee, vs. Cristy Dimaano y Tipdas, Accused-Appellant.

FACTS

Accused-appellant Cristy Dimaano was charged with attempted transportation of dangerous drugs under Republic Act No. 9165 . The prosecution alleged that on November 13, 2002, at the Manila Domestic Airport, Non-Uniformed Personnel Florence Bilugot, while frisking Dimaano, felt a hard object near her buttocks. Upon inspection in a restroom, a plastic sachet containing a white crystalline substance was found concealed in Dimaano’s underwear. Bilugot testified that Dimaano identified the substance as “shabu.” The sachet was turned over to SPO2 Reynato Ragadio, who then brought Dimaano and the evidence to the aviation security office and later to PDEA agents.
The defense centered on alleged breaks in the chain of custody. A critical inconsistency emerged: NUP Bilugot testified she seized only one plastic sachet from Dimaano, while SPO2 Ragadio recalled receiving two sachets from Bilugot. The defense argued this discrepancy created reasonable doubt regarding the identity and integrity of the corpus delicti. Furthermore, the prosecution failed to present Dimaano’s airline ticket and did not comply with the witness requirements for the inventory under Section 21 of RA 9165.

ISSUE

Whether the inconsistencies in the testimonies of the prosecution witnesses and the alleged lapses in the chain of custody warrant the acquittal of the accused-appellant.

RULING

The Supreme Court affirmed the conviction. The Court ruled that the inconsistency between Bilugot and Ragadio regarding the number of sachets initially seized was not fatal to the prosecution’s case. The Court emphasized that human memory is fallible and minor inconsistencies on collateral matters do not undermine the core finding that dangerous drugs were seized from the accused. The identity of the corpus delicti was preserved and established beyond reasonable doubt.
The Court held that the chain of custody was sufficiently intact. The sachet was immediately seized by Bilugot, marked, and turned over to Ragadio, who then delivered it to PDEA agents. It was subsequently examined by a forensic chemist who confirmed the substance was 13.96 grams of methamphetamine hydrochloride. The required witnesses under Section 21 were not present during the inventory, but the Court found this justified as the arrest and seizure occurred at an airport—a place of heightened security—early in the morning, making immediate compliance impracticable. The integrity and evidentiary value of the seized drugs were maintained throughout the process. Thus, the guilt of the accused for attempted transportation of dangerous drugs was proven beyond reasonable doubt.