G.R. No. 229099 . February 27, 2019.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. JOY ANGELES y AGBOLOS, Accused-Appellant.

FACTS

Accused-appellant Joy Angeles was charged with illegal sale and illegal possession of dangerous drugs. The prosecution’s evidence established that a buy-bust operation was conducted against her. P03 Raul Cayabyab acted as poseur-buyer and purchased one plastic sachet of shabu from Angeles for PHP500. Upon her arrest, two more plastic sachets were recovered from her pants pocket. The police conducted an inventory and took photographs of the seized items at the place of arrest in the presence of a Barangay Kagawad and an Assistant Provincial Prosecutor. The items were marked, and subsequent laboratory examination confirmed they contained methamphetamine hydrochloride.
The defense presented a different version, claiming Angeles was framed. She testified that she was merely waiting for a friend to return with medicine for her mother when police officers suddenly arrested her. She alleged the buy-bust story was fabricated and denied selling or possessing any illegal drugs.

ISSUE

The core issue is whether the prosecution successfully proved the guilt of the accused beyond reasonable doubt for violations of Sections 5 and 11 of Republic Act No. 9165 , particularly in establishing the identity and integrity of the seized drugs—the corpus delicti of the offenses.

RULING

The Supreme Court affirmed the conviction. The Court held that all elements of illegal sale and illegal possession were proven. The buy-bust operation was legitimate, and the arresting officers’ testimonies were credible and consistent. The Court found the defense of denial and frame-up weak and unsupported by evidence, especially against the clear and positive testimonies of the police officers.
Crucially, the Court ruled that the chain of custody of the seized drugs was preserved. While the defense argued non-compliance with Section 21 of RA 9165, the Court found that the procedural requirements were substantially followed. The marking, inventory, and photography were conducted immediately at the place of arrest in the presence of the required witnesses—a barangay official and a prosecutor. This presence ensured the integrity of the process from seizure to laboratory examination. The prosecution thus established an unbroken chain of custody, proving the identity and integrity of the drugs presented in court as the same ones seized from the accused. The penalties imposed by the lower courts were affirmed.