G.R. No. 237977, August 19, 2019
People of the Philippines, Plaintiff-Appellee vs. Nomer Wisco y Failano, Accused-Appellant

FACTS

The prosecution’s evidence established that a buy-bust operation was conducted against accused-appellant Nomer Wisco based on a confidential informant’s report. PO1 Rosal acted as the poseur-buyer and, upon meeting Wisco, handed marked money in exchange for a plastic sachet of suspected shabu. Upon Rosal’s pre-arranged signal, Wisco was apprehended after a brief chase. A second sachet was recovered from him during a frisk. The seized items were marked at the place of arrest in the presence of barangay officials, then submitted to the crime laboratory, where they tested positive for methamphetamine hydrochloride.
Wisco denied the accusation, claiming he was merely buying food when police officers accosted him without cause. He alleged that the drugs were planted, and the inventory was staged after he was brought back to the scene. The Regional Trial Court found him guilty of illegal sale of dangerous drugs, a ruling affirmed by the Court of Appeals.

ISSUE

Whether the Court of Appeals erred in affirming Wisco’s conviction despite alleged irregularities in the chain of custody of the seized drugs.

RULING

The Supreme Court affirmed the conviction. The Court meticulously examined the chain of custody and found it unbroken. All links were duly established: first, the seizure and marking of the drugs immediately after the sale and arrest in the presence of barangay officials; second, their turnover to the investigating officer; third, their submission to the forensic chemist for examination; and fourth, their presentation in court as evidence. The prosecution successfully accounted for each crucial transfer.
The defense of denial and frame-up was rejected for being inherently weak and unsupported by clear and convincing evidence. The Court held that the testimonies of the police officers on the buy-bust operation were credible and straightforward, prevailing over Wisco’s bare allegations. The integrity and evidentiary value of the corpus delicti were preserved. The minor inconsistency regarding who delivered the drugs to the laboratory—a detail not material to proving the elements of the crime—did not create reasonable doubt. All elements of illegal sale were proven: the identity of the buyer and seller, the object and consideration, and the delivery of the illicit drugs.