GR 179710; (June, 2010) (Digest)
G.R. No. 179710; June 29, 2010
PEOPLE OF THE PHILIPPINES, Appellee, vs. ALDRIN BERDADERO y ARMAMENTO, Appellant.
FACTS
An Information was filed against appellant Aldrin Berdadero for the illegal sale of shabu. The prosecution’s evidence established that based on a tip, police officers organized a buy-bust operation. A poseur-buyer successfully purchased two plastic sachets from the appellant. Upon the pre-arranged signal, the arresting officers apprehended Berdadero and recovered the marked money. The seized items were marked, recorded in the police blotter, and later confirmed by laboratory examination to be methamphetamine hydrochloride.
The appellant denied the accusation, claiming he was a victim of a frame-up. He testified that men posing as locksmiths entered his home and later arrested him without cause, denying that any drugs were recovered from him. The Regional Trial Court convicted him, a decision affirmed by the Court of Appeals.
ISSUE
The core issues were whether the buy-bust operation was legitimate and whether the prosecution proved the appellant’s guilt beyond reasonable doubt despite alleged non-compliance with the custody and disposition procedures under Section 21 of Republic Act No. 9165.
RULING
The Supreme Court denied the appeal and affirmed the conviction. The Court ruled that all elements of illegal sale of dangerous drugs were established: the identity of the buyer and seller, the object of the sale, and the delivery and payment. The testimonies of the police officers, who were eyewitnesses to the transaction, were credible and sufficient to prove the crime.
On the procedural issue, the Court held that while strict compliance with Section 21 of R.A. 9165 is ideal, it may be excused under justifiable grounds. The defense’s failure to timely raise the issue of non-compliance during trial was significant. More importantly, the prosecution successfully established the integrity and evidentiary value of the seized drugs through an unbroken chain of custody. The items were properly marked at the police station, submitted for laboratory testing, and positively identified in court. The non-presentation of the poseur-buyer was not fatal, as the testimonies of the other officers provided direct evidence of the sale. The penalty of life imprisonment and a fine of ₱500,000.00 was upheld.