GR 184056; (November, 2012) (Digest)
G.R. No. 184056; November 26, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. GEORGE EYAM y WATANG, Accused-Appellant.
FACTS
Accused-appellant George Eyam was charged with illegal possession of methylamphetamine hydrochloride (shabu) under Section 11, Article II of Republic Act No. 9165. The prosecution evidence established that during a buy-bust operation in Makati City, police officers apprehended Eyam. Upon search, they found in his possession two plastic sachets containing a white crystalline substance. The substance was later confirmed by forensic analysis to be shabu.
Eyam denied the charges, claiming he was merely framed. He argued that the prosecution failed to establish the integrity and identity of the seized drugs, alleging irregularities in the chain of custody. Specifically, he contended that the police officers did not immediately mark the seized items at the place of arrest and that there were gaps in the documentation of their transfer.
ISSUE
Whether the Court of Appeals erred in affirming accused-appellant’s conviction for illegal possession of dangerous drugs.
RULING
The Supreme Court affirmed the conviction. The Court held that all elements of illegal possession of dangerous drugs were duly established: (1) the accused was in possession of an item identified as a prohibited drug; (2) such possession was not authorized by law; and (3) the accused freely and consciously possessed the drug. The positive identification by the apprehending officers and the forensic chemist’s report conclusively proved the nature of the seized substance as shabu.
On the chain of custody, the Court ruled that while the implementing rules of RA 9165 outline procedural safeguards, non-compliance does not automatically invalidate seizure or render evidence inadmissible. The law requires that the integrity and evidentiary value of the seized items be preserved, not perfect adherence to procedure. The prosecution successfully demonstrated an unbroken chain through testimonies detailing the seizure, marking, laboratory submission, and testing. The alleged marking delay and documentation gaps did not create reasonable doubt about the identity of the corpus delicti, as there was no evidence of tampering, substitution, or bad faith. Eyam’s defense of frame-up was rejected for being unsubstantiated. Possession of the drug created prima facie evidence of knowledge, which he failed to rebut. Thus, his guilt was proven beyond reasonable doubt.