G.R. No. 205741, July 23, 2014
People of the Philippines, Plaintiff-Appellee, vs. Reyman Endaya y Laig, Accused-Appellant.

FACTS

Accused-appellant Reyman Endaya y Laig was charged with illegal sale and illegal possession of methamphetamine hydrochloride (shabu) under Sections 5 and 11, Article II of R.A. No. 9165. The prosecution’s evidence established that on November 20, 2002, a buy-bust operation was conducted by police operatives in Mataasnakahoy, Batangas, following a week of surveillance based on a report of appellant’s drug activities. A civilian asset, acting as poseur-buyer, handed marked money to appellant in exchange for one plastic sachet of shabu. Upon the pre-arranged signal, appellant was arrested. A body search at the scene yielded the marked money. At the police station, a further search of appellant’s wallet yielded eight more plastic sachets of shabu. The seized items were marked, inventoried in the presence of appellant and required witnesses (a clerk of court, municipal counselor, barangay captain, NGO representative, sangguniang bayan members, and a media representative), photographed, and submitted for laboratory examination, which confirmed the presence of shabu. Appellant denied the charges, claiming he was forcibly taken from a beer garden, threatened, and framed by the police officers who planted the drugs.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction for illegal sale and illegal possession of dangerous drugs.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court held that all elements of illegal sale and illegal possession of dangerous drugs were proven beyond reasonable doubt. The buy-bust operation was validly conducted, and the identity, integrity, and evidentiary value of the seized drugs were preserved through an unbroken chain of custody. The marking, physical inventory, and photographing of the seized items were done in the presence of appellant and the required witnesses under Section 21 of R.A. No. 9165, ensuring the corpus delicti’s integrity. Minor inconsistencies in the testimonies of prosecution witnesses did not affect their credibility or the core facts of the crimes. Appellant’s denial and frame-up defense, unsupported by clear and convincing evidence, could not prevail over the positive identification by the police officers and the presumption of regularity in the performance of official duty. The penalties imposed by the trial court, as affirmed by the Court of Appeals, were upheld.