G.R. No. 191266 ; June 6, 2011
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. DARIUS BAUTISTA y ORSINO @ DADA, Accused-Appellant.

FACTS

The accused-appellant, Darius Bautista, was charged with violating Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) for the alleged sale of 0.034 gram of methamphetamine hydrochloride (“shabu”) on October 15, 2004, in Manila. The case was jointly tried with a related case against his brother-in-law, Armando Marcos, who was later acquitted.
The prosecution’s version, based on the testimonies of Police Officers PO2 Jonathan Ruiz and PO2 Crispino Ocampo, was that a buy-bust operation was organized based on a tip from a confidential informant. PO2 Ruiz acted as the poseur-buyer, using a marked one hundred-peso bill. The team proceeded to Mata Street, Tondo, Manila. PO2 Ruiz and the informant approached “Dada” (Bautista), who, after being introduced as a buyer, handed the marked money to Bautista in exchange for a plastic sachet taken from Bautista’s pocket. PO2 Ruiz then identified himself as a police officer, gave the pre-arranged signal, and arrested Bautista. The marked money was recovered from Bautista’s pocket, and the seized plastic sachet was marked “DBO” (Bautista’s initials) and later submitted for laboratory examination, which confirmed it contained shabu.
The defense presented a different account. Bautista testified that on the evening in question, he was inside a neighbor’s house playing video karera with Marcos and others when about eight police officers arrived, announced themselves, frisked those present, and arrested only him and Marcos. Defense witnesses Irene Manabat (a vendor present at the scene) and Anna Marie Ignacio (the video karera operator) corroborated that the arrest occurred at the video karera location, not on the street, and that Bautista and Marcos were arrested there after resisting. Marcos also testified that he and Bautista were arrested at the video karera after being asked about its owner.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt the guilt of the accused-appellant for the illegal sale of dangerous drugs, particularly considering the credibility of the witnesses and the integrity of the chain of custody of the seized evidence.

RULING

The Supreme Court affirmed the conviction. The Court found the testimonies of the prosecution witnesses, PO2 Ruiz and PO2 Ocampo, to be clear, consistent, and credible, establishing the essential elements of the illegal sale of shabu: (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 detailed narration of the buy-bust operation by PO2 Ruiz was deemed credible and prevailed over the defenses of denial and frame-up, which were unsupported by clear and convincing evidence.
The Court also ruled that the chain of custody of the seized drug was sufficiently established. The marking of the plastic sachet with “DBO” immediately after seizure at the scene by PO2 Ruiz, its turnover to the investigator, and its subsequent submission to the crime laboratory for examination, which confirmed it was shabu, preserved its integrity and evidentiary value. The defense failed to show any ill motive on the part of the police officers to falsely accuse the appellant. The alleged inconsistencies in the testimonies of the defense witnesses and the fact that the video karera operator (an illegal activity) was not arrested cast doubt on the defense’s narrative.
Therefore, the Court upheld the decisions of the Regional Trial Court and the Court of Appeals, finding accused-appellant Darius Bautista y Orsino guilty beyond reasonable doubt of violating Section 5, Article II of R.A. No. 9165 .