G.R. No. 216014 . March 14, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. EDWIN SANCHEZ Y SALVO A.K.A. “DADA,” ACCUSED-APPELLANT.

FACTS

The prosecution’s evidence established that on August 10, 2008, a buy-bust operation was conducted in Calapan City, Oriental Mindoro, targeting a certain “Dada.” IO1 Kathleen Diocampo acted as the poseur-buyer. Upon meeting the accused-appellant Edwin Sanchez, she handed marked money in exchange for a sachet of shabu. Upon her pre-arranged signal, the team arrested Sanchez. A body search yielded the marked money and an additional sachet of shabu. The seized items were marked, inventoried at the barangay hall in the presence of a barangay official and a DOJ representative, and later confirmed by forensic examination to be methamphetamine hydrochloride.
The defense presented a different version. Sanchez testified that he was merely having a drinking session when armed persons invited him to the PDEA office. He claimed he voluntarily went, provided personal information, and was only later shown the marked money and drugs before being declared under arrest. He alleged the inventory was conducted after his arrest and not immediately at the place of seizure.

ISSUE

Whether the prosecution successfully proved the guilt of the accused-appellant for illegal sale and possession of dangerous drugs beyond reasonable doubt, particularly in light of alleged irregularities in the chain of custody of the seized items.

RULING

Yes, the conviction is affirmed. The Court found that all elements of illegal sale and illegal possession of dangerous drugs were proven. The identity of the buyer and seller, the object and consideration, and the delivery were established through the credible testimony of the poseur-buyer. For possession, the fact that an additional sachet was found on Sanchez’s person after a lawful arrest was sufficiently proven.
Regarding the chain of custody, the Court ruled that the procedural requirements under Section 21 of Republic Act No. 9165 were substantially complied with. The marking was done by the poseur-buyer at the barangay hall shortly after the arrest. The inventory and photography were conducted in the presence of the required witnesses—a barangay official and a DOJ representative. While the inventory was not conducted at the exact place of arrest, the integrity and evidentiary value of the seized items were preserved. The prosecution provided a justifiable ground for the procedural deviation, explaining that the team moved to the barangay hall due to the lack of a suitable table at the roadside scene and to ensure the presence of the necessary witnesses. The established chain of custody from seizure to forensic examination remained unbroken, and the defense failed to present clear evidence of tampering or bad faith. Thus, the guilt of the accused-appellant was proven beyond reasonable doubt.