G.R. No. 219086. March 19, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. BONIFACIO GAYLON Y ROBRIDILLO, A.K.A. “BONI”, ACCUSED-APPELLANT.

FACTS

The prosecution’s evidence established that on May 3, 2009, a buy-bust operation was conducted in Pasig City. PO1 Frederick Nervar acted as the poseur-buyer and was introduced to appellant Bonifacio Gaylon by a confidential informant. After appellant asked about the amount, PO1 Nervar handed over marked money amounting to ₱300.00. In exchange, appellant produced from his pocket a plastic sachet containing a white crystalline substance, which he gave to PO1 Nervar. Upon consummation of the sale, the arresting team apprehended appellant and recovered the buy-bust money. The seized item was marked, subjected to laboratory examination, and confirmed to be methamphetamine hydrochloride or shabu.
The defense presented a starkly different version, claiming appellant was resting at home when police officers forcibly arrested him without cause. He denied any involvement in a drug transaction and alleged he only learned of the charges the following day. The defense further argued that the police failed to comply with the chain of custody requirements under Section 21 of Republic Act No. 9165, citing the absence of required witnesses during inventory and alleged gaps in the handling of the seized drug.

ISSUE

Whether the prosecution successfully proved appellant’s guilt for illegal sale of dangerous drugs beyond reasonable doubt, particularly in establishing the integrity and identity of the corpus delicti through an unbroken chain of custody.

RULING

The Supreme Court affirmed the conviction. The Court held that all elements of illegal sale of dangerous drugs were present: (1) the identity of the buyer and seller, the object, and consideration; and (2) the delivery of the thing sold and the payment. PO1 Nervar’s positive and categorical testimony on the buy-bust operation was credible and sufficient to establish these elements. The Court ruled that minor procedural lapses in the chain of custody do not automatically invalidate the seizure or render the evidence inadmissible. The integrity and evidentiary value of the seized drugs were preserved. The marking of the sachet immediately at the scene by the arresting officer, its proper turnover to the investigating officer, and its subsequent submission to the crime laboratory for examination constituted a sufficiently unbroken chain. The presumption of regularity in the performance of official duties by the police officers stands in the absence of clear and convincing evidence of ill motive or bad faith, which the defense failed to provide. Appellant’s defenses of denial and frame-up, being unsupported and self-serving, cannot prevail over the positive identification by the prosecution witness.