G.R. No. 237850 , September 16, 2020
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. RAYMOND BUESA Y ALIBUDBUD, ACCUSED-APPELLANT.

FACTS

The prosecution’s evidence established that based on a tip from a confidential agent, a buy-bust team was formed with PO2 Jessie Abad as the poseur-buyer. On April 25, 2016, in Bay, Laguna, PO2 Abad successfully purchased a sachet of shabu from accused-appellant Raymond Buesa. Upon arrest, a preventive search yielded four more sachets. The items were marked at the scene. The team then proceeded to the police station where an inventory was conducted in the presence of a media representative and a barangay kagawad. Chemistry reports confirmed the substances were methamphetamine hydrochloride.
Buesa presented a different version, claiming he was arbitrarily apprehended by armed men while on his motorcycle, brought to a police station, coerced into admitting a crime, and later brought to a subdivision where he was forced to point to items before being photographed with them. He denied any involvement in the sale or possession of illegal drugs and asserted the charges were fabricated.

ISSUE

The core issue is whether the prosecution proved Buesa’s guilt for illegal sale and possession of dangerous drugs beyond reasonable doubt, particularly in light of the defense of frame-up and alleged irregularities in the chain of custody.

RULING

The Supreme Court affirmed the conviction. The Court found the prosecution successfully established all elements of illegal sale and illegal possession. The detailed testimony of PO2 Abad on the buy-bust transaction and the subsequent recovery of additional drugs was credible and consistent. The defense of frame-up was rejected, as it was uncorroborated and inherently weak, failing to overcome the presumption of regularity in the performance of official duties by the police officers.
Regarding the chain of custody, the Court ruled that the integrity and evidentiary value of the seized items were preserved. The marking was done immediately at the place of arrest. While the physical inventory and photography were conducted at the police station, this deviation was justified because the team was in an accident-prone area. The prosecution satisfactorily explained this, and the integrity of the evidence was maintained as the required witnesses—a media representative and a barangay official—were present during the inventory. The links in the chain of custody from seizure to laboratory examination were unbroken. Thus, the guilt of the accused-appellant was proven beyond reasonable doubt.