G.R. No. 198452 ; February 19, 2014
People of the Philippines, Plaintiff-Appellee, vs. Vicente Rom, Accused-Appellant.

FACTS

Accused-appellant Vicente Rom was charged with illegal sale of shabu, illegal possession of shabu, and maintenance of a drug den. The charges stemmed from a buy-bust operation on August 31, 2000, in Cebu City. Based on confidential information, a police team was formed with PO2 Martinez as the poseur-buyer. Martinez approached Rom’s residence, requested to buy shabu worth ₱100, and was handed a plastic sachet. After the exchange of the marked money, Martinez gave a pre-arranged signal, leading to Rom’s arrest. A subsequent search yielded four more sachets from Rom’s wallet. The prosecution presented police witnesses who testified to the details of the operation and the chain of custody of the seized items.
Rom denied the accusations, claiming he was merely a tricycle driver who was framed. He testified that on the night in question, he was at a neighbor’s house and was suddenly arrested by policemen who forced him to open his own house, where they allegedly planted the evidence. His neighbor corroborated his alibi. The defense argued that the prosecution failed to prove his guilt beyond reasonable doubt and to establish an unbroken chain of custody for the seized drugs.

ISSUE

Whether the prosecution successfully proved the guilt of the accused-appellant for the crimes of illegal sale and possession of dangerous drugs and maintenance of a drug den beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the testimonies of the police officers credible, consistent, and straightforward. The buy-bust operation was validly conducted, and the elements of illegal sale and illegal possession of dangerous drugs were duly established through the poseur-buyer’s testimony and the corroborating accounts of his teammates. The Court upheld the presumption of regularity in the performance of official duties by the arresting officers, which was not sufficiently rebutted by the defense’s claims of frame-up, a defense viewed with disfavor for being easily fabricated.
Regarding the chain of custody, the Court ruled it was sufficiently established. The marked money and seized sachets were immediately marked at the scene by the arresting officers. The items were then turned over to the investigator, who prepared the request for laboratory examination. The forensic chemist confirmed the contents were shabu. While the ideal procedure was not perfectly followed, the integrity and evidentiary value of the seized items were preserved, as there was no evidence of tampering, alteration, or substitution. The minor lapses did not constitute a break in the chain that would exonerate the accused. The penalties imposed by the Court of Appeals were affirmed.