G.R. No. 198820 ; December 10, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RENATO LAPASARAN y MEDINILLA a.k.a. “MAO”, Accused-Appellant.

FACTS

On September 12, 2006, a buy-bust operation was conducted against appellant Renato Lapasaran in Taguig City based on reports of his illegal drug activities. PO1 Alexander Saez acted as the poseur-buyer and handed two marked ₱100 bills to appellant. In exchange, appellant gave PO1 Saez a plastic sachet containing suspected shabu. Upon the pre-arranged signal, PO2 Emmanuel Maglana rushed to assist, and appellant was arrested. The police recovered the marked money and another plastic sachet from appellant. The seized items were marked, inventoried, and subjected to laboratory examination, which confirmed the presence of methylamphetamine hydrochloride.
Appellant was charged with illegal sale and illegal possession of dangerous drugs under Sections 5 and 11, Article II of Republic Act No. 9165 . The Regional Trial Court found him guilty beyond reasonable doubt, a decision affirmed by the Court of Appeals. Appellant appealed to the Supreme Court, arguing the prosecution failed to establish the identity and integrity of the seized drugs due to alleged non-compliance with the chain of custody requirements under Section 21 of RA 9165.

ISSUE

Whether the prosecution successfully established the identity and integrity of the seized dangerous drugs, thereby proving appellant’s guilt beyond reasonable doubt for illegal sale and possession.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court held that the prosecution adequately established an unbroken chain of custody. The arresting officers immediately marked the seized sachets at the place of arrest with “RML” (for the sold item) and “RML-1” (for the possessed item). An inventory was conducted on the same day, and the items were forwarded to the crime laboratory for examination, which yielded positive results for shabu. The Court ruled that while the inventory was not conducted at the police station or in the presence of a media representative, a Department of Justice representative, and an elected official, the police substantially complied with the procedural requirements. The integrity and evidentiary value of the evidence were preserved, as the marking at the scene immediately upon confiscation ensured the drugs’ identity was not compromised. The defense failed to present evidence of bad faith, ill motive, or tampering by the police officers, who are presumed to have performed their duties regularly. Thus, appellant’s guilt for both illegal sale and illegal possession was proven beyond reasonable doubt.