G.R. No. 186527 ; June 29, 2010
PEOPLE OF THE PHILIPPINES, Appellee, vs. ROY PAMPILLONA Y REBADULLA, Appellant.

FACTS

The prosecution’s evidence established that a buy-bust operation was conducted against appellant Roy Pampillona based on a tip from a confidential informant. PO2 Erwin Bautista acted as the poseur-buyer and was introduced to Pampillona. After Pampillona asked how much he would buy, PO2 Bautista handed a marked P100 bill in exchange for a plastic sachet. Upon giving a pre-arranged signal, the backup team arrested Pampillona and recovered the marked money from him. The seized sachet was marked and later confirmed by forensic examination to contain Methylamphetamine Hydrochloride or shabu.
The defense presented a starkly different version. Pampillona claimed he was arrested inside his home without cause. He alleged the charge was a frame-up orchestrated by a certain “Manny,” a police asset who lost money to him in a card game and sought revenge. The Regional Trial Court convicted Pampillona of violating Section 5 of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002), sentencing him to life imprisonment and a fine. The Court of Appeals affirmed the conviction.

ISSUE

The core issue is whether the prosecution successfully proved Pampillona’s guilt for the illegal sale of dangerous drugs beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court held that the prosecution satisfactorily established all elements of illegal sale: the identity of the buyer and seller, the object and consideration, and the delivery of the drugs and payment. The testimonies of the police officers involved in the buy-bust operation were found credible, consistent, and deserving of full faith and credit. The Court emphasized that in the absence of evidence showing ill motive on the part of the arresting officers, their testimonies are presumed to have been performed regularly.
The Court rejected Pampillona’s defense of frame-up, noting it is a common defense in drug cases that must be proven with strong and convincing evidence, which he failed to provide. His alternative claim of an alibi was likewise dismissed for being weak and unsubstantiated. The Court also addressed the non-compliance with the strict chain of custody procedure under Section 21 of R.A. 9165, specifically the absence of an elected public official, media, and DOJ representative during the inventory. The Court ruled this did not automatically invalidate the seizure, as the integrity and evidentiary value of the seized item were preserved. The apprehending officers provided justifiable grounds for the procedural lapse, citing the early morning hour of the operation, and the prosecution demonstrated an unbroken chain of custody from seizure to laboratory examination. Thus, the guilt of the appellant was proven beyond reasonable doubt.