G.R. No. 191396; April 17, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. MARILYN AGUILAR y MANZANILLO, Accused-Appellant.

FACTS

On December 1, 2004, two Informations were filed against Marilyn Aguilar y Manzanillo (Aguilar) before the Pasay City RTC for violations of Sections 5 (sale) and 11 (possession), Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). The charges stemmed from an alleged buy-bust operation on November 30, 2004, where Aguilar, also known as “Baby Mata,” was accused of selling 0.45 gram of shabu to a poseur-buyer and possessing an additional 0.31 gram.
The prosecution’s version, as testified by PO2 Roel Medrano, was that a week prior, he received information about Aguilar’s drug-dealing activities. A team was formed, a pre-operation report was submitted to the PDEA, and PO2 Medrano was designated as the poseur-buyer. On November 30, 2004, around 6:20 p.m., with an informant, he met Aguilar at Pildera, Pasay City. After a brief conversation, Aguilar accepted two marked ₱500 bills and handed over a plastic sachet of shabu. Upon the pre-arranged signal, back-up officers arrested Aguilar. A search yielded the buy-bust money and another sachet of shabu from her pocket. The seized items were marked and later examined by P/Insp. Angel Timario, who confirmed they contained methylamphetamine hydrochloride.
The defense presented a different account. Aguilar testified that she was accosted and handcuffed by police officers around 10:00 a.m. on November 30, 2004, while waiting for a jeepney with her niece, Gerolyn Lazaro. She claimed she was brought to the police station where officers demanded money and asked her to identify another drug pusher named “Lilit.” She denied the buy-bust operation occurred, asserting she was already detained at the time it was alleged to have happened. Lazaro corroborated Aguilar’s testimony regarding the morning arrest.

ISSUE

The core issue is whether the prosecution proved Aguilar’s guilt for illegal sale and possession of dangerous drugs beyond reasonable doubt, which hinges on the credibility of the conflicting testimonies and the integrity of the chain of custody of the seized drugs.

RULING

The Supreme Court affirmed the decisions of the Court of Appeals and the Regional Trial Court, finding Aguilar guilty beyond reasonable doubt.
The Court upheld the credibility of the prosecution witnesses, particularly PO2 Medrano, whose detailed and consistent testimony on the buy-bust operation was found credible and worthy of belief. The defense of frame-up was rejected for being unsubstantiated and inherently weak. The defense’s claim of an arrest at 10:00 a.m. was inconsistent with the evidence, including the police blotter entry showing the arrest occurred in the evening following the buy-bust.
Regarding the chain of custody, the Court ruled that the integrity and evidentiary value of the seized drugs were preserved. PO2 Medrano immediately marked the seized sachets at the scene with “RM-1” and “RM-2.” The items were then personally delivered to the crime laboratory on the same day for examination, which yielded positive results for shabu. The Court found that the prosecution accounted for each link in the chain: from seizure, to marking, to laboratory examination. While the handling between the arresting officer and the investigator was not explicitly detailed, the Court deemed the chain of custody unbroken as the same officer who seized and marked the items also delivered them to the forensic chemist. The defense failed to present evidence of tampering or bad faith.
Consequently, the Court affirmed the penalties imposed by the RTC: for violation of Section 5 (sale), life imprisonment and a ₱500,000 fine; for violation of Section 11 (possession), imprisonment of twelve years and one day to fourteen years and four months and a ₱300,000 fine. The confiscated drugs were ordered forfeited in favor of the government.