G.R. No. 187483, April 14, 2010
ARNEL BALARBAR y BIASORA, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

On May 26, 2005, police officers from the Dagupan City Police Station conducted surveillance in the Muslim Area, Bonuan, Tondaligan, Dagupan City, a known area for drug activities. At around 2:30 p.m., PO2 Manaois and PO1 Aquino saw petitioner Arnel Balarbar coming out from the house of a known drug pusher. When PO1 Aquino asked him where he was from, petitioner ignored the question and continued walking. As the officers followed him, petitioner dropped a plastic sachet, which, upon verification, contained shabu. PO2 Manaois held petitioner’s hand and asked if the sachet was his; petitioner denied ownership. After being informed of his constitutional rights, he was brought to the police station. The confiscated sachet was marked and submitted to the crime laboratory, where examination confirmed it contained shabu. Petitioner was charged with Violation of Article II, Section 11 of Republic Act No. 9165 (possession of dangerous drugs). At trial, petitioner denied the charge, claiming frame-up, and asserted he was merely looking for friends when the police accused him of owning the sachet they picked up from the street. The Regional Trial Court convicted petitioner, sentencing him to imprisonment of twelve years and one day to twenty years and a fine of ₱300,000. The Court of Appeals affirmed the conviction.

ISSUE

Whether the Court of Appeals erred in affirming the decision of the Regional Trial Court finding petitioner guilty beyond reasonable doubt of the crime charged, particularly regarding the establishment of the identity of the confiscated illegal drug.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court held that the factual findings of the trial court, affirmed by the appellate court, are generally conclusive and binding. It ruled that non-compliance with the custody and disposition requirements under R.A. No. 9165, under justifiable grounds, does not invalidate the seizure if the integrity and evidentiary value of the seized items are properly preserved. In this case, the integrity of the seized shabu was preserved: the plastic sachet was properly marked, submitted for examination, and its identity, quantity, and quality remained untarnished. The integrity of evidence is presumed preserved unless bad faith, ill will, or tampering is shown, and petitioner failed to overcome the presumption of regularity in the handling of exhibits by public officers. Thus, the prosecution proved petitioner’s guilt beyond reasonable doubt for illegal possession of shabu. However, the penalty was modified in accordance with the Indeterminate Sentence Law. Petitioner is sentenced to an indeterminate penalty of twelve years and one day as minimum to fourteen years and eight months as maximum, and a fine of ₱300,000.00.