G.R. No. 238906, November 05, 2018
People of the Philippines, Plaintiff-Appellee, vs. Federico Cuevas y Martinez, Accused-Appellant.

FACTS

This case stemmed from a buy-bust operation conducted by police operatives in coordination with the PDEA against accused-appellant Federico Cuevas. The prosecution alleged that Cuevas sold a sachet of shabu to a poseur-buyer. Upon his arrest, a search incidental thereto yielded two more plastic sachets of shabu and various drug paraphernalia. The seized items were marked, inventoried, and photographed at the barangay hall in the presence of a barangay councilor, a DOJ representative, and a media representative. They were then submitted to the crime laboratory, where they tested positive for methamphetamine hydrochloride.
Cuevas presented a different version, claiming he was at home with his family when police officers mistakenly arrested him, believing him to be “Tolit Garcia.” He alleged that after finding no drugs in his house, the officers beat him, brought him to the station, and forced him to admit ownership of a box. He denied any involvement in the drug trade.

ISSUE

Whether the Court of Appeals erred in affirming Cuevas’s conviction for Illegal Sale and Illegal Possession of Dangerous Drugs.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court held that all elements of the crimes were proven. For illegal sale, the transaction between Cuevas as the seller and the poseur-buyer was established, including the delivery of the shabu and payment. For illegal possession, Cuevas was found in conscious possession of two additional sachets of shabu without legal authority, recovered during a valid search incidental to a lawful arrest.
Crucially, the Court ruled that the chain of custody over the seized drugs was sufficiently preserved. The buy-bust team complied with the procedure under Section 21 of RA 9165. The items were immediately marked at the scene. The inventory and photography were conducted in the presence of the required witnesses—an elected public official, a DOJ representative, and a media representative—which constituted substantial compliance. The stipulated procedure ensures the integrity and evidentiary value of the corpus delicti from seizure to presentation in court. The defense of frame-up was rejected for being unsubstantiated and for failing to overcome the presumption of regularity in the performance of official duties by the apprehending officers, whose testimonies were found credible by the trial court.