G.R. No. 253186 . September 21, 2022.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. WU JIAN CAI AND JIANG HUO ZAO, ACCUSED, CHEN JUNYUE, ACCUSED-APPELLANT.

FACTS

The case stemmed from a buy-bust operation on June 12, 2009, targeting a drug syndicate. A police poseur-buyer, accompanied by a confidential informant, negotiated to buy two kilograms of shabu. The transaction occurred inside a vehicle where accused-appellant Chen Junyue was observed in a nearby car. A co-accused, Jojit Ilao, eventually handed a backpack containing the drugs to the poseur-buyer. Upon the pre-arranged signal, the buy-bust team moved in. Chen Junyue and another accused were arrested in their vehicle. A subsequent search of their car yielded a significant quantity of shabu contained in boxes. Chen Junyue was charged with illegal sale and illegal possession of dangerous drugs under Republic Act No. 9165 .
The Regional Trial Court convicted Chen Junyue. The Court of Appeals affirmed the conviction, holding that the prosecution established the elements of the crimes and the integrity of the seized drugs. Chen Junyue appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, particularly contesting the chain of custody of the evidence and his alleged conspiracy with his co-accused.

ISSUE

The core issue is whether the Court of Appeals erred in affirming Chen Junyue’s conviction for illegal sale and illegal possession of dangerous drugs despite alleged breaks in the chain of custody and insufficient proof of conspiracy.

RULING

The Supreme Court dismissed the appeal and affirmed the conviction. On the charge of illegal sale, the Court found all elements present: the transaction occurred, the poseur-buyer received the backpack containing drugs, and the boodle money was presented. Chen Junyue’s active participation was established through the testimony of the poseur-buyer, who detailed Chen Junyue’s presence and movements coordinating with his co-accused during the drug delivery, proving conspiracy.
Regarding illegal possession, the drugs were found in the vehicle Chen Junyue was driving, and he failed to justify lawful possession. The Court ruled that the chain of custody was substantially complied with. While the forensic chemist who conducted the initial qualitative test was not presented, the quantitative analyst who confirmed the weight and presence of methamphetamine hydrochloride testified. The Court emphasized that the testimony of the forensic chemist is not indispensable if the prosecution presents other witnesses who can establish the integrity of the evidence. The marking, inventory, and photographing were done at the police station in the presence of Chen Junyue, his co-accused, and their counsel, satisfying the witness requirements under the law. The procedural deviations, such as the absence of the testimony of the evidence custodian after the drugs were transferred to the Philippine Drug Enforcement Agency, were deemed not to cast doubt on the evidence’s integrity, as representative samples remained in court custody. Thus, the guilt of the accused-appellant was proven beyond reasonable doubt.