G.R. No. 225219. June 11, 2018
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. RICO DE ASIS Y BALQUIN, ACCUSED-APPELLANT.

FACTS

On June 1, 2011, a PDEA team in Cagayan de Oro City conducted a buy-bust operation against Rico de Asis based on information from a civilian informant. Agent Rubietania Gacus, acting as poseur-buyer, was introduced to the appellant at his residence. She handed him marked money in exchange for one plastic sachet of suspected shabu. After the transaction, Gacus signaled the team, which then arrested De Asis. A search incident to arrest yielded four more sachets of suspected shabu from his pocket and various drug paraphernalia from a table inside the house. The seized items were immediately marked, inventoried in the presence of a barangay kagawad and a media representative, photographed, and later submitted to the crime laboratory, which confirmed the presence of methamphetamine hydrochloride.
The Regional Trial Court convicted De Asis for illegal sale and possession of dangerous drugs and possession of drug paraphernalia under Republic Act No. 9165. The Court of Appeals affirmed the convictions for illegal sale and possession but acquitted him for possession of paraphernalia due to the prosecution’s failure to prove he owned or controlled the items found on the table. De Asis appealed to the Supreme Court, questioning the validity of his arrest and the integrity of the seized drugs.

ISSUE

The core issue is whether the prosecution successfully proved the elements of the crimes and preserved the integrity and evidentiary value of the seized dangerous drugs through an unbroken chain of custody.

RULING

The Supreme Court affirmed the convictions. The Court held that all elements of illegal sale and illegal possession of dangerous drugs were established. The buy-bust operation was legitimate, and the arrest was lawful as it was made after a consummated sale. The defense of frame-up was rejected for lack of clear and convincing evidence of any improper motive on the part of the arresting officers.
Crucially, the Court ruled that the chain of custody over the seized drugs was intact. The marking, physical inventory, and photography of the items were conducted immediately at the place of arrest in the presence of the required witnesses—a barangay official and a media representative—as mandated by Section 21 of RA 9165. The prosecution presented a coherent account of how the evidence was handled from seizure, marking, and turnover to the laboratory, and finally to its presentation in court. This established an unbroken chain that preserved the identity and integrity of the corpus delicti. The penalties imposed by the CA—life imprisonment and a P500,000 fine for illegal sale, and an indeterminate prison term of 12 years and 1 day to 14 years and 8 months plus a P300,000 fine for illegal possession—were affirmed as correct.