G.R. No. 259181, August 2, 2023
People of the Philippines, Plaintiff-Appellee, vs. Nhelmar Mendiola y Martin @ “Honda,” Noel Mendiola y Ponce @ “Noel,” and Glen Ramos y Akiatan @ “Glen,” Accused-Appellants.

FACTS

Accused-appellants Nhelmar Mendiola, Noel Mendiola, and Glen Ramos were convicted for violation of Section 5, Article II of Republic Act No. 9165 (the Comprehensive Dangerous Drugs Act of 2002), as amended by RA 10640. An additional charge for violation of Section 11 of the same law was upheld against accused-appellant Noel Mendiola. The case stemmed from a buy-bust operation where Police Officer 3 Junjun Mataverde purchased a plastic bag containing a white crystalline substance from the accused-appellants. PO3 Mataverde also recovered from accused-appellant Noel a black bag containing another plastic bag of suspected shabu. The seized items were immediately marked at the place of arrest. An inventory and photography of the seized items were conducted at the site in the presence of the accused-appellants, a barangay kagawad, and a media representative. The marked items were then turned over to the investigating officer, SPO3 Rolando Aligier, Jr., who prepared the necessary documents. Subsequently, PO3 Mataverde turned over the items to the PNP Crime Laboratory for examination. PCI Alejandro de Guzman, the forensic chemist, received the specimens, conducted tests which confirmed the presence of shabu, placed his own markings on the items, and turned them over to an evidence custodian. PCI de Guzman later retrieved the items from the custodian and presented and identified them in court.

ISSUE

Whether the prosecution successfully established an unbroken chain of custody of the seized dangerous drugs, thereby proving the corpus delicti and the identity of the evidence beyond reasonable doubt.

RULING

Yes. The prosecution successfully proved an unbroken chain of custody in strict compliance with the procedure under Section 21, Article II of RA 9165, as amended. The Concurring Opinion underscored that the chain of custody rule is not difficult to comply with and was meticulously followed in this case. The links were established as follows: (1) Seizure and immediate marking at the place of arrest, with inventory and photography conducted on-site in the presence of the accused and the required insulating witnesses (a barangay official and a media representative); (2) Turnover of the seized items from the apprehending officer to the investigating officer; (3) Turnover from the investigating officer to the forensic chemist for laboratory examination, which confirmed the items were shabu; and (4) Turnover and submission of the marked illegal drugs from the forensic chemist to the court, where they were duly identified. The strict compliance with the chain of custody rule preserved the integrity and evidentiary value of the corpus delicti, foreclosing opportunities for planting, contaminating, or tampering with the evidence. Therefore, the conviction of the accused-appellants was affirmed.