G.R. No. 182059; July 4, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. CAMILO D. NICART and MANUEL T. CAPANPAN, Accused-Appellants.

FACTS

Based on a tip, a buy-bust operation was conducted against a certain “Milo” (Camilo Nicart) on July 2, 2003. PO1 Joy Decena acted as poseur-buyer and was introduced to Nicart. Decena handed a marked P100 bill to Nicart, who then crossed the street and gave the money to Manuel Capanpan. Capanpan handed a plastic sachet to Nicart, who in turn gave it to Decena. Upon receiving the sachet, Decena arrested Nicart. The backup team then arrested Capanpan, from whom they recovered another plastic sachet and the marked money. Forensic examination confirmed both sachets contained methylamphetamine hydrochloride (shabu). The defense presented a different narrative, claiming the accused were merely buying milk and were arbitrarily arrested without a buy-bust operation.
The Regional Trial Court convicted Nicart of illegal sale under Section 5 of Republic Act No. 9165 and Capanpan of both illegal sale and illegal possession under Sections 5 and 11. The Court of Appeals affirmed the convictions. The accused appealed to the Supreme Court, arguing the prosecution failed to prove their guilt beyond reasonable doubt and failed to establish the integrity of the seized drugs.

ISSUE

The core issue is whether the guilt of accused-appellants Camilo Nicart and Manuel Capanpan for violations of Republic Act No. 9165 was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the convictions. The Court found the testimonies of the police officers credible and consistent, detailing a clear chain of events for the buy-bust operation. Nicart acted as the broker who received the marked money from the poseur-buyer and delivered the shabu from Capanpan, making them conspirators in the illegal sale. Capanpan’s possession of another sachet of shabu and the marked money upon arrest substantiated the charge of illegal possession. The defense of frame-up was rejected for lack of clear and convincing evidence of improper motive on the part of the arresting officers.
Regarding the chain of custody, the Court ruled that while the officers did not strictly comply with the inventory and witness requirements under Section 21 of RA 9165, the integrity and evidentiary value of the seized items were preserved. The prosecution established an unbroken chain through testimony on the marking, turnover, and stipulation on the forensic examination. The marked money and sachets were identified in court. The Court emphasized that non-compliance with Section 21 does not automatically invalidate seizures if the prosecution can prove the integrity of the evidence. Here, the prosecution successfully demonstrated an unbroken chain of custody from seizure to laboratory examination, thereby proving the corpus delicti of the crimes.