G.R. No. 227187. March 04, 2019.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ERIC L. SEVILLA, ACCUSED-APPELLANT.

FACTS

The prosecution’s evidence established that on May 26, 2010, a buy-bust operation was conducted against appellant Eric Sevilla in Panabo City. A confidential informant arranged a transaction where PDEA agent IO1 Julius Magdadaro acted as poseur-buyer. Upon meeting Sevilla, Magdadaro handed a marked Php100 bill in exchange for two packets of suspected marijuana. Upon the pre-arranged signal, back-up officers arrested Sevilla. A search incident to arrest yielded from his person the marked money and from his bag ten more packets of suspected marijuana. The seized items were marked at the scene, placed in an evidence pouch, and later subjected to inventory and photography at the police station in the presence of required witnesses, including a media representative, an elected official, a DOJ representative, and appellant’s representative. The items were then forwarded to the crime laboratory, where forensic examination confirmed them to be marijuana.
Appellant presented a starkly different version, claiming he was simply accosted upon arriving home from work, falsely accused of selling drugs, and that the evidence was planted. He denied ownership of the seized packets. The Regional Trial Court found him guilty of illegal sale and possession of dangerous drugs under Sections 5 and 11 of Republic Act No. 9165, a decision affirmed by the Court of Appeals. Appellant appealed to the Supreme Court, arguing the prosecution failed to prove his guilt and to establish an unbroken chain of custody of the seized drugs.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction for violations of Sections 5 and 11 of Republic Act No. 9165, despite alleged irregularities in the chain of custody of the seized drugs.

RULING

The Supreme Court dismissed the appeal and affirmed the conviction. The Court held that all elements of illegal sale and illegal possession of dangerous drugs were proven beyond reasonable doubt. The buy-bust operation was legitimate, with the poseur-buyer positively identifying appellant as the seller, the consummation of the sale through the exchange of marijuana for marked money, and the subsequent recovery of more marijuana from appellant’s possession. The defense of denial and frame-up, being inherently weak, could not prevail over the clear and categorical testimonies of the police officers, who were presumed to have performed their duties regularly in the absence of evidence to the contrary.
Crucially, the Court ruled that the chain of custody was sufficiently established and preserved the integrity and evidentiary value of the seized items. The prosecution meticulously documented the links: immediate marking at the place of arrest, inventory and photography at the police station with the presence of an elected official, a media representative, a DOJ representative, and appellant’s own representative, followed by laboratory examination. While the law requires an inventory immediately after seizure and confiscation, the conduct of the inventory at the police station under the circumstances, and in the presence of the required witnesses, constituted substantial compliance. The integrity of the evidence was thus preserved from the moment of seizure until its presentation in court. The penalties imposed—life imprisonment and a P500,000 fine for illegal sale, and an indeterminate prison term of 12 years and 1 day to 13 years plus a P300,000 fine for illegal possession—were affirmed as correct.