G.R. No. 246461 , July 28, 2020
People of the Philippines, Plaintiff-Appellee, v. Rosendo Leaño y Leaño, Accused-Appellant.

FACTS

Accused-appellant Rosendo Leaño y Leaño was charged with violations of Section 5 (Illegal Sale) and Section 11 (Illegal Possession), Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). The charges stemmed from a buy-bust operation on July 1, 2016, in Balanga City, Bataan. Based on information from a confidential informant, a police team was formed with PO1 Paul Nemen M. Pajarin as the poseur-buyer. Appellant agreed to sell PHP 500.00 worth of shabu at a designated meeting place. During the transaction, appellant handed PO1 Pajarin one heat-sealed plastic sachet containing white crystalline substance in exchange for the marked money. Upon arrest, appellant was frisked, leading to the recovery of the marked money and a Marlboro box containing two more similar sachets. The seized items were marked at the scene in the presence of appellant and a backup officer. An inventory was conducted at the police station in the presence of appellant, a barangay kagawad, and a Department of Justice representative. The items were then submitted to the crime laboratory, where forensic examination confirmed the substance was methamphetamine hydrochloride (shabu). Appellant’s urine test also yielded a positive result for methamphetamine use. Appellant denied the charges, claiming he was arbitrarily arrested, beaten, and framed by the police while he was out buying food and vitamins. The Regional Trial Court convicted appellant. The Court of Appeals affirmed the conviction.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction despite alleged procedural lapses in the conduct of the buy-bust operation and in the custody of the seized drugs.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction. The Court held that all elements of illegal sale and illegal possession of dangerous drugs were proven beyond reasonable doubt. The buy-bust operation was legitimate, and the integrity and evidentiary value of the seized items were preserved. The Court found that the apprehending officers substantially complied with the chain of custody requirements under Section 21 of RA 9165. The marking of the seized items was done immediately at the place of arrest in the presence of appellant. The inventory and photography were conducted at the police station with the required witnesses present—a barangay official and a DOJ representative. The absence of a media representative was justified, as the law only requires the presence of any of the three witnesses (an elected public official, a representative from the DOJ, and a representative from the media) to ensure the integrity of the process. The defense of frame-up and denial was rejected for being unsupported by clear and convincing evidence and for being inherently weak against the positive testimonies of the police officers. The penalties imposed by the trial court were affirmed: for illegal sale (Section 5), life imprisonment and a fine of PHP 500,000.00; for illegal possession (Section 11), imprisonment of 15 years and 1 day to 20 years and a fine of PHP 300,000.00.