G.R. No. 186387 ; August 31, 2011
THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN MENDOZA y VICENTE, Accused-Appellant.

FACTS

The prosecution’s evidence established that based on information from a confidential informant, a buy-bust operation was conducted on April 14, 2005. PO2 Edgar Antolin acted as the poseur-buyer and met the accused, Juan Mendoza y Vicente, at the stairs of the Cresencia Barangay Hall in Baguio City. After PO2 Antolin handed over ₱1,000.00, the accused gave him two sachets containing white crystalline substance. Upon the pre-arranged signal, the backup team arrested the accused. A body search yielded five more similar sachets from the accused’s pants pocket. The seized items tested positive for methamphetamine hydrochloride (shabu) in both a preliminary test and a confirmatory test conducted by the PNP Crime Laboratory.
The accused presented a different version, claiming he was arbitrarily apprehended by SPO4 Sison while walking home, brought to the police station for questioning about a photograph and a certain Gary Chua, and subsequently subjected to a drug test and medical examination without being informed of an arrest for drug possession.
The Regional Trial Court (RTC) of Baguio City, Branch 61, found the accused guilty beyond reasonable doubt for violations of Section 5 (sale) and Section 11 (possession), Article II of Republic Act No. 9165 . The Court of Appeals (CA) affirmed the RTC decision with modification, adjusting the fine for the possession charge.

ISSUE

1. Whether the procedures for the custody and disposition of confiscated dangerous drugs under Section 21 of R.A. No. 9165 were complied with.
2. Whether the guilt of the accused-appellant was proven beyond reasonable doubt.

RULING

The Supreme Court denied the appeal and affirmed the CA decision.
1. On the Chain of Custody: The Court ruled that compliance with the chain of custody rule was sufficiently established. The required links were met: (a) the seizure and marking of the illegal drugs by the apprehending officer (PO2 Antolin); (b) the turnover of the seized drugs to the investigating officer/team leader (SPO4 Sison); (c) the turnover by the investigating officer to the forensic chemist for laboratory examination; and (d) the submission of the marked drugs from the forensic chemist to the court. The testimonies of PO2 Antolin and SPO4 Sison corroborated the handling of the evidence. The forensic chemist’s report confirmed the substances were shabu.
2. On Proof Beyond Reasonable Doubt: The Court held that all elements of the crimes were satisfactorily proven. For illegal sale, the identities of the buyer (PO2 Antolin), seller (accused), object (shabu), consideration (₱1,000.00), and the delivery and payment were established. For illegal possession, it was proven that the accused was in possession of prohibited drugs, such possession was not authorized by law, and he freely and consciously possessed them. The positive testimonies of the police officers prevailed over the accused’s denial and frame-up claim, which were unsupported by clear and convincing evidence.
The penalties imposed by the CA were sustained: life imprisonment and a ₱500,000.00 fine for illegal sale (Sec. 5), and an indeterminate penalty of 12 years and 1 day to 14 years plus a ₱300,000.00 fine for illegal possession (Sec. 11).