G.R. No. 83329. December 10, 1991.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. OSCAR D. FABIAN, accused-appellant.

FACTS

Accused-appellant Oscar Fabian was convicted for selling and delivering methylamphetamine hydrochloride or “shabu” in violation of R.A. No. 6425, as amended, and sentenced to life imprisonment. The prosecution evidence established that a buy-bust operation was conducted on March 11, 1987, in Las Piñas. P/Pat. Rolando Geronimo acted as poseur-buyer and, after being introduced by an informant, received an aluminum foil packet of shabu from Fabian. Upon Geronimo’s pre-arranged signal, team members arrested Fabian and recovered a second packet from his pants pocket. The items were marked, and a receipt was signed by Fabian. Forensic analysis confirmed the substance was shabu.
The defense presented a contrasting version, alleging the police forcibly entered his home, planted evidence, and attempted to extort money. Fabian also pointed to a discrepancy between the weight description on the evidence receipt (“approximately 1/8 of a gram”) and the forensic report (28.9 mg and 2.1 mg), suggesting evidence substitution.

ISSUE

The core issue is whether the prosecution proved Fabian’s guilt for the illegal sale of dangerous drugs beyond reasonable doubt, amidst challenges to evidence authenticity and alleged procedural irregularities.

RULING

The Supreme Court affirmed the conviction. The discrepancy in weight did not establish evidence substitution. The description “approximately 1/8 of a gram” on the receipt was a rough estimate by the arresting officers, not a precise scientific measurement. The forensic chemist’s exact milligram weights derived from laboratory instruments. This variance is inconsequential, as the integrity of the evidence was preserved through a clear chain of custody. Patrolman Geronimo positively identified the seized items in court.
The Court upheld the trial court’s assessment of witness credibility, favoring the straightforward narrative of the police officers over the denial and frame-up claim of the accused. The defense of frame-up, being easily fabricated, requires strong evidence to prevail, which was not presented. The signing of the receipt (Exhibit “B”) was treated merely as an identification act, not a custodial confession requiring prior Miranda warnings, as the arrest and seizure had already occurred. The prosecution successfully established all elements of the crime.