G.R. No. 231981 , August 20, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. HENRY BANQUILAY y ROSEL, Accused-Appellant

FACTS

On May 2, 2012, a buy-bust operation was conducted in Caibiran, Biliran, targeting accused-appellant Henry Banquilay. PDEA Agent IO1 Floro Katangkatang acted as the poseur-buyer. After the informant introduced Katangkatang, Banquilay asked for the money. Upon receiving the marked ₱1,000 bill, Banquilay handed over one heat-sealed plastic sachet containing a white crystalline substance. Katangkatang then gave the pre-arranged signal, leading to Banquilay’s arrest by the team led by IO3 Alex Tablate. The accused was brought to the police station where an inventory was conducted in the presence of Barangay Captain Leo Insigne and a media representative. The seized sachet was marked and later submitted to the crime laboratory, where it tested positive for methamphetamine hydrochloride or shabu.
The defense presented a different version. Banquilay claimed he was merely waiting for a bus when two men in civilian attire suddenly accosted and arrested him without cause. He denied selling drugs and alleged the evidence was planted. His neighbor, Christy Porpogo, corroborated his claim of being arbitrarily arrested. The Regional Trial Court found Banquilay guilty of illegal sale of dangerous drugs under Section 5 of Republic Act No. 9165 . The Court of Appeals affirmed the conviction, prompting this appeal.

ISSUE

Whether the Court of Appeals erred in affirming the conviction despite alleged breaches in the chain of custody of the seized dangerous drug.

RULING

The Supreme Court dismissed the appeal and affirmed the conviction. The Court held that all elements of illegal sale of dangerous drugs were proven: the identity of the buyer and seller, the object and consideration, and the delivery of the drugs. The testimony of the poseur-buyer, detailing the transaction, was clear and consistent. Regarding the chain of custody, the Court ruled it was unbroken. The marked sachet was immediately seized by the poseur-buyer, who retained custody until the inventory at the police station in the presence of the required witnesses—an elected official and a media representative. The sachet was then turned over to the receiving officer at the crime lab, who secured it before its examination by the forensic chemist.
The Court emphasized that the integrity and evidentiary value of the seized item were preserved. Minor procedural deviations, such as the absence of a Department of Justice representative during inventory, do not automatically invalidate the seizure, provided the integrity of the evidence is maintained. The prosecution successfully established every link in the chain, from seizure to laboratory examination to presentation in court. The defense failed to present clear evidence of bad faith, ill motive, or tampering to overcome the presumption of regularity in the performance of official duties by the arresting officers. Thus, the guilt of the accused-appellant was proven beyond reasonable doubt.