G.R. No. 217979 . February 22, 2017.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. ADAL TON ARCE y CAMARGO, Accused-Appellant.

FACTS

Accused-appellant Adalton Arce was charged with illegal sale and possession of dangerous drugs under Sections 5 and 11, Article II of R.A. 9165. The prosecution alleged that based on a tip, a buy-bust operation was conducted. PO1 Maquinta, acting as poseur-buyer, purchased one matchbox of marijuana from Arce for a marked ₱100 bill. Upon consummation of the sale, Arce was arrested. A subsequent body search yielded seven more matchboxes of marijuana. The seized items were marked, inventoried, and photographed at the place of arrest in the presence of representatives from the media, the DOJ, PDEA, and a barangay official. Forensic examination confirmed the substances were marijuana.
The defense presented a different version, claiming Arce was merely drinking at a dike when he was arbitrarily arrested, beaten, and framed. He denied selling or possessing any illegal drugs and alleged the evidence was planted. The RTC found him guilty, a ruling affirmed by the CA, prompting this appeal.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant’s conviction for violations of Sections 5 and 11 of R.A. 9165.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court found the prosecution successfully established all elements of illegal sale and illegal possession of dangerous drugs. For the sale, the transaction with the poseur-buyer was clearly proven. For possession, the recovery of the seven additional matchboxes from Arce’s person, following a lawful arrest, was established. The Court upheld the credibility of the police officers’ testimonies, noting no ill motive was shown for them to falsely accuse Arce.
Crucially, the Court ruled that the chain of custody of the seized drugs was preserved. The required witnesses under Section 21 of R.A. 9165—a representative from the media, the DOJ, and an elected public official—were present during the physical inventory and photographing of the evidence at the place of arrest. This compliance with the witness requirement, as stipulated by the defense, negated any claim of tampering. The integrity and evidentiary value of the seized items were thus intact from seizure to presentation in court. The defense of frame-up, being unsubstantiated, deserved no credence. The Court only modified the RTC ruling to correct a typographical error, specifying the drug sold was marijuana, not shabu.