Facts:

In this case, Rosana Asiatico y Sta. Maria (petitioner) was implicated in a drug-related crime and found guilty of illegal possession of dangerous drugs, specifically methamphetamine hydrochloride, commonly known as "shabu." The incident occurred on January 19, 2005, in Mandaluyong City, Philippines. The petitioner and her co-accused, Aldrin Estrella y Sta. Maria, were charged with a violation of Section 11, Article II of Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002. The Regional Trial Court (RTC), Branch 214 in Mandaluyong City, convicted both individuals on March 12, 2007, sentencing them to twelve years and one day of imprisonment and imposing a fine of P300,000 each.

The prosecution presented a series of events leading up to the arrest. It began when an informant reported the illegal drug activities of the petitioner and Aldrin. A police buy-bust operation was organized, and during the operation at approximately 8:00 PM, the police posed as

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Facts:

Procedural Background and Charges

• The case originates from a Petition for Review on Certiorari under Rule 45 by petitioner Rosana Asiatico y Sta. Maria.
• Rosana was convicted by the RTC, Branch 214 in Mandaluyong City for illegal possession of dangerous drugs under Section 11, Article II of RA 9165 (Comprehensive Dangerous Drugs Act of 2002).
• The RTC convicted both Rosana and her co-accused, Aldrin Estrella y Sta. Maria, in two separate Informations; however, only Rosana appealed.
• The petition challenges the August 31, 2010 Decision and January 6, 2011 Resolution of the Court of Appeals (CA) that affirmed the RTC’s decision and denied Rosana’s motion for reconsideration.

The Facts of the Buy-Bust Operation

• On January 19, 2005, at around 8:00 p.m., an informant reported the illegal drug trade activities involving accused-appellant “Joy” (Rosana) and Aldrin in Barangay Bagong Silang, Mandaluyong City.
• Based on the information, a buy-bust team was organized comprising:
• PO2 Jorge Gorgonia (team leader)
• PO1 Sadjid Angara – designated as the poseur-buyer who signaled by removing his cap.
• Other officers including PO1 Antonio Madlangbayan, PO1 Rommel Alfaro, PO1 Oscar Escudero, and PO1 Pedro Sangada served as backup.
• The team, with the informant, proceeded to J. Luna Street where Rosana was allegedly selling “shabu.”
• During the operation, PO1 Angara, acting as a buyer, approached Rosana, initiating the supposed transaction for shabu, although Rosana initially only had P200 worth of shabu when P300 was requested.
• Shortly thereafter, Aldrin appeared with two plastic sachets purportedly containing shabu, but then he backed out, triggering the operation’s predetermined signal by PO1 Angara removing his cap.
• Following the signal, PO1 Madlangbayan arrested both Rosana and Aldrin, conducted separate frisks, and recovered one plastic sachet from Rosana and two from Aldrin.

Evidence Handling and Chain of Custody

• The recovered evidence consisted of heat-sealed plastic sachets containing a total of 0.05 gram (Rosana) and two sachets for Aldrin containing shabu.
• The physical evidence was handled with due precautions:
• Each sachet was wrapped with newspapers and labeled (“Joy” for Rosana and “ASE-1/ASE-2” for Aldrin).
• After documentation, the evidence was submitted to the Mandaluyong City PNP Crime Laboratory for forensic examination by Police Senior Inspector Isidro L. Carino.
• The chain of custody was maintained through successive transfers—from the arresting officers, to the station records, and eventually to the trial prosecutor and the trial court as evidence.

Trial, Appellate Proceedings, and Sentencing

• At trial, Rosana pleaded not guilty but was convicted beyond reasonable doubt by the RTC, which imposed a penalty of imprisonment of twelve (12) years and one (1) day along with a fine of PhP 300,000.
• The CA affirmed the RTC’s findings and conviction in its decision dated August 31, 2010, primarily relying on the testimony (particularly of PO1 Angara) and the established chain of custody of the seized drugs.
• The CA ruled that any procedural lapses regarding custody and disposition of the seized drugs did not render the drugs inadmissible as evidence, as the evidentiary value and integrity were preserved.
• While the conviction was affirmed, the CA modified the sentence to conform with the Indeterminate Sentence Law (ISL). Instead of a fixed term, Rosana was sentenced to an indeterminate imprisonment ranging from a minimum of twelve (12) years and one (1) day to a maximum of fourteen (14) years and eight (8) months.

Defense Version of Events

• Rosana and Aldrin contended that on the night of January 19, 2005, they were at Rosana’s residence preparing for dinner when armed men in civilian clothes forcibly entered and conducted a search.
• They claimed that the drugs were only seen later at the Drug Enforcement Unit office, and they denied any involvement in selling or possessing drugs prior to that point.
• Despite these claims, the evidence gathered by the buy-bust operation and the subsequent testimony of the police officers supported the prosecution’s case.

Issue:

• Whether the Court of Appeals gravely erred in affirming the conviction of petitioner, despite the prosecution’s alleged failure to overthrow the presumption of innocence in her case.
• Whether the Court of Appeals gravely erred in affirming the conviction despite alleged shortcomings in establishing an unbroken chain of custody of the confiscated dangerous drugs.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)