G.R. No. 206366 , August 13, 2014
PEOPLE OF THE PHILIPPINES, Appellee, vs. EDUARDO BALAQUIOT y BALDERAMA, Appellant.

FACTS

On June 11, 2008, appellant Eduardo Balaquit was arrested in a buy-bust operation conducted by police officers in Camiling, Tarlac. He was charged with illegal sale of shabu under Section 5 of Republic Act No. 9165 . The prosecution presented evidence including one heat-sealed plastic sachet containing 0.049 grams of white crystalline substance marked “JSE-EBB” and dated “11 June 2008,” and Chemistry Report D-184-08 confirming the substance as methamphetamine hydrochloride. Prosecution witnesses PO3 Jay Espiritu (the poseur-buyer) and SPO1 Noli Daraman testified that after a week-long surveillance and confirmation from their Chief Intelligence Officer (CIO), they conducted the operation. PO3 Espiritu successfully bought the shabu from appellant using a marked ₱500 bill, after which appellant was arrested. The seized item was marked at the police station, and an inventory was conducted with barangay officials. Police chemist Jebie Timario confirmed the substance was shabu. The defense, relying on appellant’s testimony and that of his brother Exequil, denied the sale and claimed a frame-up, alleging appellant was accosted by armed men, forced to sign a report, and detained. The Regional Trial Court convicted appellant, sentencing him to life imprisonment and a ₱500,000 fine, which the Court of Appeals affirmed.

ISSUE

1. Whether the trial and appellate courts erred in giving credence to the prosecution’s version of events.
2. Whether the prosecution proved the corpus delicti of the offense beyond reasonable doubt, particularly regarding the chain of custody of the seized drugs.

RULING

The Supreme Court denied the appeal and affirmed the conviction.
1. The RTC and CA did not err in crediting the prosecution’s evidence. Appellant’s cited circumstances—(a) non-presentation of the CIO as a witness, (b) absence of coordination with the Philippine Drug Enforcement Agency (PDEA), and (c) the claim that police should have applied for a search warrant instead—do not undermine the legitimacy of the buy-bust operation. The testimony of the CIO would merely be corroborative; prior coordination with PDEA is not a mandatory condition for a valid buy-bust operation as ruled in People v. Roa; and the choice of legal means is within police discretion. Appellant’s denial cannot overcome the affirmative testimonies of credible police officers.
2. The corpus delicti was proven beyond reasonable doubt. The prosecution established an unbroken chain of custody: PO3 Espiritu testified to buying and retrieving the plastic sachet from appellant, marking it at the station, and forwarding it to the crime laboratory, where Timario confirmed it as shabu. The failure to mark the item immediately at the place of arrest does not automatically break the chain, as the integrity and evidentiary value of the evidence were preserved. The Court found no evidence of tampering, and the testimonies sufficiently tracked the custody of the seized drugs from apprehension to laboratory examination.