G.R. No. 236304 , November 05, 2018
People of the Philippines, Plaintiff-Appellee, vs. Arman Santos Gutierrez a.k.a. “Arman,” Accused-Appellant.

FACTS

This case stemmed from a buy-bust operation conducted against accused-appellant Arman Santos Gutierrez on May 30, 2015, in Binmaley, Pangasinan. The police team, with PO1 Antonio Tadeo, Jr. as the poseur-buyer, successfully purchased one plastic sachet of suspected shabu from Gutierrez in exchange for a marked P500 bill. Immediately after the transaction, the appellant was apprehended. The seized item was marked, and an inventory and photography were conducted at the place of arrest in the presence of barangay officials and a Provincial Prosecutor. A media representative from ABS-CBN was also present. The sachet was then forwarded to the crime laboratory, where Forensic Chemical Officer PCI Myrna Todeño confirmed the substance was methamphetamine hydrochloride.
Gutierrez denied the charges, claiming he was merely buying mangoes when he was flagged down by police, forcibly taken to a house, assaulted, and framed. He alleged the drugs were planted on him after he lost consciousness. The Regional Trial Court found him guilty beyond reasonable doubt of illegal sale of dangerous drugs under Section 5 of Republic Act No. 9165 , sentencing him to life imprisonment and a fine. The Court of Appeals affirmed this conviction, prompting the instant appeal.

ISSUE

Whether the Court of Appeals erred in affirming Gutierrez’s conviction despite alleged non-compliance with the chain of custody requirements under Section 21 of RA 9165.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court held that the prosecution successfully established all elements of illegal sale of dangerous drugs and preserved the integrity of the corpus delicti through an unbroken chain of custody. The Court meticulously examined the procedure from seizure to presentation in court. The buy-bust team immediately marked the seized sachet at the scene. The inventory and photography were conducted in the presence of the required witnesses: an elected barangay official, a representative from the National Prosecution Service (the Provincial Prosecutor), and a media representative. This strict compliance with the witness requirement under the law, as amended by RA 10640, effectively guarded against any suspicion of evidence switching or planting.
The Court emphasized that the presence of these insulating witnesses is crucial to remove any doubt regarding the identity and integrity of the seized drugs. Here, their presence was duly established. Furthermore, the forensic chemist testified to receiving the properly marked specimen, conducting the examination, and resealing it for safekeeping, thus accounting for every link in the custody chain. The defense of frame-up was correctly rejected for being unsubstantiated and for failing to overcome the presumption of regularity in the police officers’ performance of their duties, which was bolstered by their adherence to procedural safeguards. Consequently, the identity and evidentiary value of the dangerous drug were preserved beyond moral certainty, warranting the affirmation of Gutierrez’s guilt.