GR 190342; (March, 2012) (Digest)
G.R. No. 190342 ; March 21, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. CIPRIANO CARDENAS y GOFRERICA, Accused-Appellant.
FACTS
On January 6, 2003, police officers from Camp Crame conducted a buy-bust operation in Payatas, Quezon City, acting on a tip regarding accused-appellant Cipriano Cardenas’s drug peddling. PO3 Rene Enteria acted as the poseur-buyer, using a marked ₱100 bill. Upon introduction by a confidential informant, Cardenas sold a plastic sachet of shabu to Enteria in exchange for the marked money. Enteria gave the pre-arranged signal, leading to Cardenas’s immediate arrest. A subsequent body search yielded two more plastic sachets from his pocket. The seized items, marked at the scene, were confirmed by forensic analysis to be methylamphetamine hydrochloride.
Cardenas presented a different account, claiming he was arbitrarily arrested while walking home and that he never saw any drugs during his investigation. He denied the sale occurred. The Regional Trial Court convicted him for violating Section 5 of Republic Act No. 9165 (illegal sale of dangerous drugs), a decision affirmed by the Court of Appeals. He appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt and to establish the chain of custody of the seized drugs.
ISSUE
Whether the Court of Appeals erred in affirming accused-appellant’s conviction for the illegal sale of dangerous drugs.
RULING
The Supreme Court denied the appeal and affirmed the conviction. The Court held that all elements of illegal sale of dangerous drugs were proven: (1) the identity of the buyer and seller, the object, and the consideration; and (2) the delivery of the thing sold and the payment. The testimonies of the poseur-buyer and the team leader were credible, consistent, and constituted sufficient proof of the transaction. The Court found no ill motive for the officers to falsely accuse the appellant.
Regarding the chain of custody, the Court ruled that the integrity and evidentiary value of the seized items were preserved. The marking of the sachets immediately after seizure at the scene by the arresting officer, PO3 Palacio, constituted the initial crucial link in the chain. This physical marking served to isolate the evidence and prevent switching or contamination. The subsequent turnover to the investigating officer and the forensic chemist for laboratory examination, which yielded a positive result for shabu, completed an unbroken chain. The Court emphasized that while the ideal procedure under Section 21 of R.A. 9165 was not followed to the letter, the prosecution satisfactorily established that the integrity of the evidence had been maintained. The appellant’s bare denial, unsupported by clear and convincing evidence, could not prevail over the positive identification by the police officers.