G.R. No. 243793, November 27, 2019
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. JOESON AGUILAR Y CIMAFRANCA, ACCUSED-APPELLANT.

FACTS

Accused-appellant Joeson Aguilar y Cimafranca was charged with illegal sale of dangerous drugs under Section 5, Article II of Republic Act No. 9165 . The prosecution evidence established that on August 18, 2015, in Dumaguete City, a buy-bust operation was conducted against a certain “Tonton” based on a tip from a confidential informant. PO1 Crisanto Panggoy acted as the poseur-buyer and agreed to buy P20,000.00 worth of shabu from “Tonton.” At the appointed time and place, “Tonton” (later identified as Aguilar) handed over two heat-sealed plastic sachets containing white crystalline substance to PO1 Panggoy in exchange for marked money. Aguilar was immediately arrested. The seized sachets were marked at the scene, and an inventory was conducted at the police station in the presence of Aguilar, a media representative, a Department of Justice representative, and a barangay official. The items were then forwarded to the crime laboratory, where they tested positive for methamphetamine hydrochloride. Aguilar denied the charges, claiming he was illegally arrested inside his house by armed men who ransacked it and later framed him. The Regional Trial Court found him guilty, a decision affirmed by the Court of Appeals.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for illegal sale of dangerous drugs, despite alleged non-compliance with the chain of custody rule under Section 21 of Republic Act No. 9165 .

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction. The Court held that all elements of illegal sale of dangerous drugs were proven: (1) the identity of the buyer and seller, the object, and the consideration; and (2) the delivery of the thing sold and the payment. The testimonies of the prosecution witnesses were credible and consistent. Regarding the chain of custody, the Court ruled that the integrity and evidentiary value of the seized drugs were preserved. The marking was done immediately at the place of arrest. The inventory and photography were conducted in the presence of the required witnesses. The drugs were then turned over to the investigating officer, submitted to the crime laboratory for examination, and eventually presented in court. The procedure substantially complied with Section 21 of RA 9165. The defense of frame-up was rejected for lack of clear and convincing evidence. The penalty of life imprisonment and a fine of Five Hundred Thousand Pesos (P500,000.00) was upheld.