G.R. No. 209212 , February 10, 2016
People of the Philippines, Plaintiff-Appellee, vs. Romel Sapitula y Paculan, Accused-Appellant.

FACTS

Acting on a tip, a buy-bust operation was organized against accused-appellant Romel Sapitula. On June 16, 2011, PO3 Ardie Palabay, acting as poseur-buyer, met Sapitula at a pre-arranged location. Sapitula handed over a heat-sealed plastic sachet containing a white crystalline substance, and PO3 Palabay gave him marked money in exchange. Upon the pre-arranged signal, arresting officers moved in. Sapitula attempted to flee but was subdued and apprehended. The seized item was marked, inventoried, and later confirmed by forensic examination to be methamphetamine hydrochloride or shabu.
For the defense, Sapitula denied the sale. He testified that he was merely flagged down while driving his tricycle with his family, accosted by armed men who introduced themselves as policemen, and then forcibly handcuffed. He claimed the officers rubbed a substance on his hands and later presented it as evidence against him.

ISSUE

Whether the Court of Appeals correctly affirmed accused-appellant’s conviction for the illegal sale of dangerous drugs under Section 5, Article II of Republic Act No. 9165 .

RULING

The Supreme Court affirmed the conviction. The prosecution successfully established all elements of illegal sale of dangerous drugs: (1) the identity of the buyer and seller, the object, and the consideration; and (2) the delivery of the thing sold and the payment. The detailed testimony of PO3 Palabay, the poseur-buyer, credibly demonstrated the consummated transaction where Sapitula handed over the shabu in exchange for the marked money. The defense of frame-up was rejected for being unsubstantiated and inherently weak, especially when weighed against the clear and consistent narrative of the police officers, who were presumed to have performed their duties regularly.
The Court also upheld the integrity of the seized drug. The chain of custody was preserved through testimony showing the sachet was immediately marked at the scene, inventoried in the presence of a barangay official, and subsequently delivered to the crime laboratory for examination, which yielded a positive result for shabu. Any minor deviations from the strict requirements of Section 21 of R.A. 9165 did not compromise the evidence’s integrity, as the prosecution provided justifiable grounds and proved the corpus delicti’s identity and integrity beyond reasonable doubt. The penalty of life imprisonment and a fine of P500,000.00 was thus affirmed.