G.R. No. 242831 . June 22, 2022.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. VICTOR ALCIRA Y MADRIAGA ALSO KNOWN AS [A.K.A.] BUDDHA, ACCUSED-APPELLANT.

FACTS

On June 17, 2015, a buy-bust operation was conducted against Victor Alcira based on information that he was engaged in selling illegal drugs and possessed an unlicensed firearm. SPO1 Emil Norella Janairo acted as the poseur-buyer. At the target area, Alcira sold a plastic sachet of shabu to SPO1 Janairo for PHP 300.00. Upon arrest, a .38 caliber revolver was found tucked at Alcira’s waist, and two more plastic sachets of shabu were recovered from his pocket. A nearby individual, Merlen Caberos, was also found holding a sachet of shabu, and two more were recovered from her. SPO1 Janairo immediately marked the seized items at the place of arrest. An inventory was conducted witnessed by Alcira, a member of the press, and a barangay official. The items were then delivered to the crime laboratory, where forensic examination confirmed the sachets contained methamphetamine hydrochloride. Alcira was charged with illegal sale and possession of dangerous drugs under Republic Act (R.A.) No. 9165 and illegal possession of firearms under R.A. No. 10591 . The Regional Trial Court (RTC) convicted Alcira, a decision affirmed by the Court of Appeals (CA). Alcira appealed, arguing the prosecution failed to establish an unbroken chain of custody of the seized drugs.

ISSUE

Whether the Court of Appeals erred in affirming Alcira’s conviction despite the prosecution’s alleged failure to comply with the chain of custody requirements under Section 21, Article II of R.A. No. 9165 , thereby failing to prove his guilt beyond reasonable doubt.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the convictions. The Court held that the prosecution established all elements of the crimes and substantially complied with the chain of custody rule. While the arresting officers did not strictly follow the witness requirement under Section 21—as the required witnesses were not present at the time of seizure but only during the subsequent inventory—this did not invalidate the seizure. The integrity and evidentiary value of the seized items were preserved. The marking was done immediately at the place of arrest, the inventory was witnessed by the accused, a media representative, and a barangay official, and the items were properly turned over to the forensic chemist. The forensic chemist’s testimony confirmed the items examined were the same ones seized. The Court found no evidence of tampering, bad faith, or ill motive on the part of the apprehending officers. Alcira’s defenses of denial and frame-up were rejected for being unsupported by clear and convincing evidence. His conviction for illegal possession of firearms was also upheld, as he failed to present any license or authority to possess the firearm.