G.R. No. 225780. December 03, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. JAYSON TORIO Y PARAGAS @ “BABALU,” ACCUSED-APPELLANT.

FACTS

On December 18, 2012, a buy-bust operation was conducted against Jayson Torio based on a tip from a civilian asset. The team, led by SPO1 Marday Delos Santos, included a poseur-buyer and two Barangay Kagawads as witnesses. The asset purchased a plastic sachet of suspected shabu from Torio using marked money. Upon the pre-arranged signal, the team arrested Torio. A body search yielded the marked money and another plastic sachet. The seized items were marked at the scene in the presence of the Kagawads. The items were later examined and confirmed to be methamphetamine hydrochloride.
Torio denied the charges, claiming he was framed. He testified that the asset merely boarded his tricycle and that he was arrested without any transaction occurring. He alleged that the police officers later staged a photo opportunity with the drugs. He also claimed a prior misunderstanding with SPO1 Delos Santos.

ISSUE

Whether the prosecution successfully proved the guilt of the accused beyond reasonable doubt for the crimes of illegal sale and possession of dangerous drugs, despite alleged non-compliance with the chain of custody rule under Section 21 of Republic Act No. 9165.

RULING

Yes. The Supreme Court affirmed the conviction. The Court held that the prosecution established all elements of illegal sale and illegal possession of dangerous drugs. The buy-bust operation was legitimate, and the integrity and evidentiary value of the seized drugs were preserved. The Court found the testimonies of the police officers credible and consistent, while the defense of frame-up was unsubstantiated.
Regarding the chain of custody, the Court ruled that while the apprehending team did not secure the presence of a representative from the Department of Justice (DOJ) and the media during the inventory, this did not automatically invalidate the seizure. The law allows non-compliance under justifiable grounds, provided the integrity of the evidence is preserved. Here, the police officers immediately marked the seized items at the place of arrest in the presence of two elected public officials (the Barangay Kagawads) and the accused. The operation was sudden, and inviting media representatives could have compromised it. The established links in the chain—from seizure, marking, and inventory at the scene, to submission to the forensic chemist, and presentation in court—ensured the drugs’ identity and integrity were not compromised. Thus, the guilt of the accused was proven beyond reasonable doubt.