G.R. No. 233321, December 05, 2019
People of the Philippines, Appellee, vs. Roberto F. Valdez, Appellant.

FACTS

Appellant Roberto F. Valdez was charged with violations of Section 5 (Illegal Sale) and Section 11 (Illegal Possession), Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). The charges stemmed from a buy-bust operation on July 25, 2009, in Panabo City. PCPAG Glen Abellana acted as poseur-buyer and purchased two packs of dried marijuana leaves from appellant for PHP 200 using marked money. Upon the pre-arranged signal, the arresting team closed in. PO3 Adonis Estenzo frisked appellant, recovered the marked money, and seized from a paper bag appellant was carrying two additional bundles of suspected marijuana. The seized items were marked at the place of arrest. The team brought appellant and the items to the police station where an inventory and photographing were conducted in the presence of witnesses from the media, PDEA, and an elected barangay official. The items were then submitted to the crime laboratory, where examination confirmed they were marijuana. The defense presented appellant, who denied the charges, claiming he was sleeping when unknown persons entered his house, handcuffed him, and brought him to the police station where the drugs were planted.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction despite alleged breaches in the chain of custody of the seized dangerous drugs and inconsistencies in the prosecution’s evidence.

RULING

The Supreme Court denied the appeal and affirmed the convictions. 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, and the identity, integrity, and evidentiary value of the seized marijuana were preserved through an unbroken chain of custody. The marking of the items at the place of arrest, the conduct of inventory and photography in the presence of the required witnesses, and the proper turnover to and examination by the crime laboratory constituted substantial compliance with the procedural requirements of Section 21, Article II of RA 9165. The alleged inconsistencies in the testimonies of the prosecution witnesses and the variances in the recorded weights and descriptions of the seized items were minor and did not affect the core fact of the crimes. The defense of denial and frame-up, unsupported by clear and convincing evidence, could not prevail over the positive testimonies of the police officers.