G.R. No. 186467 ; July 13, 2011
People of the Philippines, Plaintiff-Appellee, vs. Jaime Gatlabayan y Batara, Accused-Appellant.

FACTS

On September 10, 2002, police officers in Rodriguez, Rizal, formed a buy-bust team based on information that accused-appellant Jaime Gatlabayan was selling illegal drugs. PO1 Jose Gordon Antonio acted as the poseur-buyer, equipped with a marked ₱100 bill. The team proceeded to Carlton Village. The asset pointed out Gatlabayan. PO1 Antonio approached him. Gatlabayan asked if he wanted “to score,” meaning to buy shabu. PO1 Antonio said yes, handed over the marked money, and received a plastic sachet containing white crystalline substance. Upon the pre-arranged signal, the backup officers arrested Gatlabayan. The marked money was recovered from his pocket. The seized item was examined by Forensic Chemist P/Insp. Joseph Perdido and found positive for methamphetamine hydrochloride. Gatlabayan was charged with illegal sale of dangerous drugs under Section 5, Article II of R.A. No. 9165 . The defense claimed he was framed, arrested while singing at a “peryahan” (fair), and brought to the station without being frisked. The Regional Trial Court convicted Gatlabayan, sentencing him to life imprisonment and a ₱500,000 fine. The Court of Appeals affirmed the conviction. Gatlabayan appealed to the Supreme Court.

ISSUE

1. Whether the prosecution proved Gatlabayan’s guilt beyond reasonable doubt for illegal sale of dangerous drugs.
2. Whether the testimonies of the prosecution witnesses were credible despite alleged inconsistencies.
3. Whether the prosecution established the chain of custody of the seized illegal drug in compliance with Section 21 of R.A. No. 9165 .

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction.
1. Guilt Proven Beyond Reasonable Doubt: The Court ruled that all elements of illegal sale of dangerous drugs were established: (a) the identity of the buyer and seller, the object, and the consideration; and (b) the delivery of the thing sold and the payment. The testimonies of PO1 Antonio, the poseur-buyer, and PO1 Jiro, corroborated by the Chemistry Report, positively identified Gatlabayan as the seller. The defense of frame-up was rejected for lack of clear and convincing evidence to overcome the presumption of regularity in the performance of official duty by the police officers, who were not shown to have been motivated by ill will.
2. Credibility of Prosecution Witnesses: The alleged inconsistencies in the testimonies of the police officers (e.g., whether the asset was inside or outside the vehicle during the operation) pertained to minor and collateral details that did not affect the core narrative of the buy-bust operation. Such inconsistencies did not impair their credibility but instead suggested they were not rehearsed.
3. Chain of Custody: The Court held that the prosecution substantially complied with the chain of custody rule under Section 21 of R.A. No. 9165 . The integrity and evidentiary value of the seized drug were preserved. PO1 Antonio, the poseur-buyer, marked the seized plastic sachet at the police station immediately after the arrest. It was then forwarded to the crime laboratory for examination, where it was received and tested by P/Insp. Perdido, who confirmed it was shabu. The failure to strictly comply with the witness requirements during the physical inventory and photographing (as the law was then newly effective) was not fatal, as the integrity of the evidence was shown to be intact from seizure to laboratory analysis. The marked money was also properly identified and presented in court.
The decision of the Court of Appeals affirming the Regional Trial Court’s judgment was upheld. Gatlabayan was found guilty beyond reasonable doubt of illegal sale of dangerous drugs and sentenced to life imprisonment and a fine of ₱500,000.