G.R. No. 223682 , October 09, 2019
THE PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ONNI ADDIN Y MADDAN, ACCUSED-APPELLANT.

FACTS

On March 16, 2010, a buy-bust operation was conducted against accused-appellant Onni Addin y Maddan in Barangay Culiat, Quezon City, based on information from a confidential informant. PO2 Joel Diomampo acted as the poseur-buyer and was given a marked PhP 500 bill. The team coordinated with the Philippine Drug Enforcement Agency (PDEA). At the target area, the informant introduced PO2 Diomampo to Addin, who then sold a sachet of suspected shabu in exchange for the marked money. Upon the pre-arranged signal, Addin was apprehended by the back-up officers, and the marked money was recovered from him. The police team immediately left the area due to perceived danger from previous shoot-outs in the Shalaam Compound. At the police station, PO2 Diomampo turned over the seized sachet to the investigator, SPO1 Jeffrey Flores, who prepared the required documents, including an Inventory of Property Seized witnessed by Addin’s relatives and a media representative. The sachet was submitted to the crime laboratory, where forensic chemist PSI May Andrea Bonifacio confirmed it contained methamphetamine hydrochloride. Addin was charged with illegal sale of dangerous drugs under Section 5, Article II of Republic Act No. 9165 . He denied the accusation, claiming he was arbitrarily arrested while at a sari-sari store. The Regional Trial Court (RTC) convicted him, and the Court of Appeals (CA) affirmed the conviction. Addin appealed to the Supreme Court, arguing the prosecution failed to establish an unbroken chain of custody due to alleged non-compliance with Section 21 of RA 9165, particularly that the inventory and photographing were not conducted at the place of arrest.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant Onni Addin y Maddan’s conviction for illegal sale of dangerous drugs despite alleged irregularities in the chain of custody.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction. The Court held that the prosecution successfully established all elements of illegal sale of dangerous drugs and preserved the integrity and evidentiary value of the seized item through a compliant chain of custody. The buy-bust operation was legitimate, and the procedural requirements under Section 21 of RA 9165 were substantially complied with. The police officers’ immediate departure from the crime scene to conduct the inventory at the police station was justified by the genuine concern for their safety in a known dangerous area. The inventory was duly witnessed by the accused’s relatives and a media representative. The marking, turnover to the investigator, laboratory examination, and presentation in court were properly documented and testified to, ensuring the seized item’s identity and integrity were not compromised. The presumption of regularity in the performance of official duty stands in the absence of clear evidence of ill motive. The defenses of denial and frame-up were rejected for being unsupported by convincing proof. Thus, accused-appellant’s guilt was proven beyond reasonable doubt.