GR 220141; (June, 2018) (Digest)
G.R. No. 220141 . June 27, 2018
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. ARNULFO BALENTONG BERINGUIL, ACCUSED-APPELLANT.
FACTS
The prosecution charged accused-appellant Arnulfo Balentong Beringuil with illegal sale of a dangerous drug under Section 5, Article II of R.A. No. 9165 . The information alleged that on February 8, 2010, in Salcedo, Eastern Samar, Beringuil sold one brick of cocaine weighing 993.00 grams to PDEA Intelligence Officer 1 Germiniano Laus, Jr. during a buy-bust operation. The transaction occurred after Beringuil personally showed the cocaine and received the boodle money, leading to his arrest. The seized item was marked “ABB-1” at the police station in the presence of a barangay official, with subsequent inventory at the PDEA office witnessed by media and DOJ representatives. Forensic examination confirmed the substance was cocaine.
Beringuil denied the accusation, claiming he was framed. He testified he was at the market to deliver belongings to a friend when he was forcibly apprehended by unidentified men. He insisted no drug transaction occurred and that the cocaine presented was not recovered from him. The Regional Trial Court convicted him, a decision affirmed by the Court of Appeals. Beringuil appealed to the Supreme Court, questioning witness credibility and the integrity of the seized drug.
ISSUE
Whether the Court of Appeals erred in affirming Beringuil’s conviction for illegal sale of dangerous drugs despite alleged inconsistencies in prosecution testimony and purported breaks in the chain of custody of the seized cocaine.
RULING
The Supreme Court denied the appeal and affirmed the conviction. The Court held that all elements of illegal sale of dangerous drugs were proven: the identity of the buyer and seller, the object and consideration, and the delivery of the illegal drug. The minor inconsistencies raised by Beringuil—pertaining to details like the time of arrival or the meeting point—were deemed trivial and did not affect the core facts of the transaction. Such minor discrepancies are natural and may even enhance witness credibility by negating any suspicion of rehearsed testimony.
On the chain of custody, the Court ruled that the integrity and evidentiary value of the seized cocaine were preserved. The marking “ABB-1” at the police station was substantiated by testimony and documentary evidence, including the inventory signed by a barangay official and photographs. The defense failed to present any evidence of tampering, bad faith, or ill will on the part of the apprehending officers. Consequently, the presumption of regularity in the performance of official duty stands. The forensic confirmation that the substance was cocaine further solidified the corpus delicti. Thus, the guilt of the accused was established beyond reasonable doubt.