G.R. No. 234156 , January 7, 2019
People of the Philippines, Plaintiff-Appellee, vs. Emmanuel Oliva y Jorjil, Bernardo Barangot y Pilais and Mark Angelo Manalastas y Gapasin, Accused-Appellants.

FACTS

A buy-bust operation was conducted against a certain “Manu” in Makati City. PO3 Luisito Marcelo acted as poseur-buyer and approached appellant Emmanuel Oliva, identified as “Manu.” After receiving the marked money, Oliva showed four plastic sachets of shabu. PO3 Marcelo, along with appellants Bernardo Barangot and Mark Angelo Manalastas, who were present to buy drugs, each took one sachet. Upon consummation, PO3 Marcelo gave the pre-arranged signal, leading to the arrest of all three appellants. A body search on Oliva yielded another sachet and the marked money. The seized items were inventoried, photographed, and submitted for laboratory examination, which confirmed the presence of methamphetamine hydrochloride.
Appellants pleaded not guilty and proffered defenses of denial and frame-up. Oliva claimed he was forcibly taken by armed men. Barangot alleged he was arrested during a drinking session. Manalastas asserted he was taken from his home. The Regional Trial Court convicted them for violations of Sections 5 (sale) and 11 (possession) of Republic Act No. 9165 . The Court of Appeals affirmed the convictions.

ISSUE

Whether the Court of Appeals erred in affirming the convictions despite alleged irregularities in the chain of custody of the seized drugs.

RULING

The Supreme Court affirmed the convictions. The Court held that the prosecution successfully established all elements of the crimes and preserved the integrity and evidentiary value of the seized items. Appellants’ arguments focused on alleged non-compliance with the witness requirement under Section 21 of RA 9165, contending that the inventory was not conducted in the presence of a representative from the media, the Department of Justice, and an elected public official. The Court ruled that while there was imperfect compliance, such did not automatically invalidate the seizure. The apprehending officers provided justifiable grounds for the absence of the required witnesses, citing the late hour of the operation and earnest efforts to secure their presence. The core requirement of establishing an unbroken chain of custody was met. The police officers properly marked, inventoried, and photographed the seized items immediately after the arrest at the barangay hall, and the forensic chemist confirmed the integrity of the specimens received. The defense of denial, being inherently weak, could not prevail over the positive and categorical testimonies of the police officers, who were presumed to have performed their duties regularly in the absence of clear evidence of ill motive.