G.R. No. 213598, July 27, 2016
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. MERCELITA ARENAS y BONZO @ MERLY, Accused-Appellant

FACTS

Accused-appellant Mercelita Arenas was charged with violations of Sections 5 (Sale) and 11 (Possession) of Article II of Republic Act No. 9165. The prosecution evidence established that based on surveillance, a buy-bust operation was conducted on August 6, 2010, in Sual, Pangasinan. PO3 Benedict Julius Rimando acted as poseur-buyer and was given two marked ₱1,000 bills. Arenas arrived at the location, and upon receiving the marked money, handed over two plastic sachets of suspected shabu to PO3 Rimando. Upon arrest, a body search yielded a third plastic sachet from Arenas. The seized items were marked at the police station in the presence of a barangay kagawad, a DOJ prosecutor, and a media representative, then submitted for laboratory examination, which confirmed the substance as methamphetamine hydrochloride.
Arenas presented a different version, claiming she was merely asked by a certain Mina to deliver a letter. She alleged that PSI Leo Llamas, whom she claimed to know, arrested her without cause at a videoke bar and that she was framed. PSI Llamas, however, denied knowing Arenas prior to the arrest or being at the alleged bar. The Regional Trial Court found Arenas guilty, a decision affirmed by the Court of Appeals, prompting this appeal.

ISSUE

The core issue is whether the prosecution successfully proved Arenas’s guilt for the illegal sale and possession of dangerous drugs beyond reasonable doubt, particularly in establishing the identity and integrity of the corpus delicti.

RULING

The Supreme Court affirmed the conviction. The Court meticulously applied the elements for illegal sale and possession of dangerous drugs. For the sale under Section 5, all elements were present: the transaction occurred, with PO3 Rimando as the buyer, Arenas as the seller, the two sachets as the object, and the marked money as consideration. For possession under Section 11, Arenas was caught in possession of a third sachet without legal authority. The Court found the chain of custody was sufficiently established. The marking, inventory, and photography were conducted at the police station immediately after seizure in the presence of the required witnesses under RA 9165—a barangay official, a media representative, and a DOJ representative—which constituted substantial compliance. The forensic chemist confirmed the integrity of the items from receipt to examination. Arenas’s defense of denial and frame-up was deemed weak and unsubstantiated, especially against the clear and consistent testimonies of the police officers who were presumed to have performed their duties regularly. The minor inconsistencies in the police officers’ testimonies regarding distances and positions were considered trivial and did not affect the core narrative of the buy-bust operation. Thus, the guilt of the accused-appellant was proven beyond reasonable doubt.