Facts:

The case, G.R. No. 212170, involves the accused-appellant Alex Escaran y Tariman (Escaran) and the plaintiff-appellee, the People of the Philippines. The case originates from charges filed on March 23, 2004, stemming from incidents occurring on the same date in Mandaue City, Philippines. On this day, Escaran was apprehended in relation to illegal activities involving the sale and possession of dangerous drugs, specifically "shabu" or methamphetamine hydrochloride. Two separate Informations were filed against Escaran: the first for violating Section 5 of Article II of Republic Act No. 9165 for illegal sale, alleging that he sold two packets of shabu weighting a total of 0.06 grams; and the second for violating Section 11 of the same law for illegal possession, which involved four additional packets with a combined weight of 0.08 grams.

During his arraignment, Escaran pleaded not guilty. The prosecution's case was built largely through testimonies from police officer

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Facts:

Procedural Background and Charges

• The case involved accused-appellant Alex Escaran y Tariman, charged with two separate drug-related offenses under Sections 5 and 11, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
• Two Informations, both dated March 23, 2004, were filed against Escaran: one for the illegal sale of dangerous drugs (two packets totaling 0.06 gram of shabu) and another for the illegal possession of dangerous drugs (four heat-sealed packets totaling 0.08 gram).

The Buy-Bust Operation and Arrest

• The buy-bust operation was initiated following a tip received from a confidential agent indicating that Escaran was selling shabu at Sitio Sapa-Sapa, Ibabao, Mandaue City.
• Key aspects of the operation included:
• A phone call made at around 7:00 p.m., followed by a surveillance that confirmed the tip.
• A briefing among police personnel led by PCI Enguerra, where plans for a buy-bust operation were formalized, including the designation of PO1 VeraAo as the poseur-buyer.
• The operation began at around 9:00 p.m. on board a service vehicle, during which PO1 VeraAo made a pretended transaction prompting Escaran to hand over two packets of shabu.
• After the transaction, Escaran was arrested on the spot and was subsequently searched, where an additional four packets of shabu were recovered from his clothing.

Handling of Evidence and Chain of Custody Issues

• The seized contraband (six packets of shabu) were marked and later transferred to the PNP Crime Laboratory for chemical analysis.
• Crucial procedural lapses were noted:
• The marking, inventory, and photographing of the seized items were not performed in the presence of the accused or his representative, nor were the required witnesses (a DOJ representative, a media representative, and an elected public official) present at the time of seizure and apprehension as mandated by Section 21 of RA 9165.
• Testimonies of PO1 VeraAo and PO1 Montebon revealed that no proper physical inventory or photographic evidence of the seized packets was generated at the scene or at the police station.
• The records indicated a breach in the “chain of custody”; there was no clear accounting for the handling of the seized items from the moment of confiscation to their presentation in court.

Defense’s Account and Arguments

• Escaran denied involvement in drug selling and provided a narrative where he claimed:
• He was waiting for his co-worker in compliance with his work schedule and was not actively engaging in any drug transaction.
• He faced coercive tactics from individuals who later revealed themselves as persons dressed as police officers, eventually leading to his arrest under duress.
• The defense further argued that procedural irregularities, particularly the failure to secure the chain of custody and the required witnesses, compromised the integrity of the evidence.

Trial Court and Court of Appeals Decisions

• The Regional Trial Court (RTC) found Escaran guilty beyond reasonable doubt for both charges and imposed penalties including life imprisonment and fixed term sentences with additional fines.
• The Court of Appeals (CA) affirmed the RTC’s decision, agreeing that the evidentiary testimony of the police officers was sufficient to establish the crimes despite procedural lapses, and modified the penalties by imposing additional fines and an adjusted term of imprisonment on each count.

Issue:

Whether the Court of Appeals erred in sustaining Escaran’s conviction for the violations of Sections 5 and 11, Article II of RA 9165 in view of the procedural lapses in handling the seized drugs.

• Does the failure to comply with the mandatory requirements of Section 21—namely, the lack of immediate inventory, marking, and photographing of seized items in the presence of the required witnesses—undermine the evidentiary value of the corpus delicti?
• Can the presumption of regularity in the performance of official duties overcome clear breaches in the chain of custody, especially when such lapses may lead to doubts about the integrity and identity of the evidence?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)