G.R. No. 188310; June 13, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. MERCIDITA T. RESURRECCION, Accused-Appellant.

FACTS

Accused-appellant Mercidita T. Resurreccion was charged with illegal sale and possession of dangerous drugs under Republic Act No. 9165. The prosecution evidence established that after surveillance, a buy-bust operation was conducted where PO2 Julius Lique acted as poseur-buyer. Appellant sold one heat-sealed plastic sachet of shabu to Lique in exchange for marked money. Upon arrest, a subsequent search yielded a film canister containing twelve more sachets. The seized items were marked at the scene, with the sold sachet marked “JBL” and the others marked “MERCY-1” to “MERCY-12,” before being turned over to the investigating officer and later submitted for laboratory examination, which confirmed the presence of methylamphetamine hydrochloride.
At trial, appellant denied the charges, claiming she was merely waiting for a ride when she was forcibly taken by individuals who demanded money and later framed her. She asserted that the prosecution failed to establish the chain of custody of the seized drugs, particularly arguing there was no testimony from the officer who received the items at the police station and that the required witnesses during inventory were absent. The Regional Trial Court convicted appellant, a ruling affirmed by the Court of Appeals.

ISSUE

Whether the prosecution successfully proved appellant’s guilt beyond reasonable doubt for the crimes of illegal sale and possession of dangerous drugs, notwithstanding the alleged lapses in the chain of custody.

RULING

Yes, the Supreme Court affirmed the conviction. The Court held that the prosecution established all elements of the crimes. For illegal sale, the elements of the transaction were proven: the identity of the buyer and seller, the object, and the consideration. For illegal possession, appellant was found in possession of the twelve additional sachets without legal authority. The Court ruled that the alleged procedural lapses in the chain of custody did not compromise the integrity and evidentiary value of the seized drugs. The marking of the items immediately at the place of arrest by the apprehending officer, PO2 Lique, was the most critical link in the chain, as it served to prevent switching or contamination. The subsequent links—the turnover to the investigator and the submission to the crime lab—were sufficiently established through documentary evidence, including the request for examination and the physical science report. The Court emphasized that while the presence of witnesses during inventory is ideal, their absence is not fatal to the prosecution’s case provided there is a justifiable ground and the integrity and identity of the evidence are preserved, which was satisfied here. The positive identification by the police officers prevailed over appellant’s bare denial.