G.R. No. 201069 - Bangko Sentral ng Pilipinas vs. Office of the Ombudsman

Kevin Belmonte y Goromeo, along with his co-accused Mark Anthony Gumba y Villaraza and Billy Joe Costales, was charged under the Comprehensive Dangerous Drugs Act of 2002 (RA 9165).
Two separate Informations were filed before the Regional Trial Court (RTC):

Criminal Case No. 8979 alleging violation of Section 5, Article II (illegal sale).
Criminal Case No. 8997 charging Gumba with violation of Section 11, Article II (possession, noting that Gumba was a minor at the time).

On November 23, 2010, in San Gabriel, La Union, the accused allegedly engaged in the sale of marijuana.
During the transaction:

The sale involved one bundle of dried marijuana fruiting tops weighing approximately 828.96 grams.
The payment was made using marked money (four pieces of ₱500 bills) prepared by the law enforcement team.

A separate allegation involved the possession of four bricks of marijuana (with individual weights ranging between 809.54 grams and 869.16 grams) totaling 3,319.43 grams.

Philippine Drug Enforcement Agency (PDEA) Agent Sharon Ominga, along with members of the Quick Reaction Force and the Police Anti-Illegal Drug Special Operation Task Group, initiated a buy-bust operation based on information from a confidential informant.
The team:

Ominga assumed the role of the poseur-buyer, while Intelligence Officer CaAero functioned as the arresting officer.
Backup officers and coordination with local police and barangay officials were involved.

The suspects were identified when one of Gumba’s companions, later identified as Costales, intervened during the staged transaction.
The confiscation of the marijuana (in bundle and brick forms) was carried out with on-site inventory, marking (Ominga’s initials, signature, and the date), photography, and subsequent transfer to the PDEA laboratory for examination.
Despite the presence of deviations (such as the absence of media and Department of Justice (DOJ) representatives during parts of the inventory process), the chain of custody was maintained as explained by the apprehending officers.

The accused presented an alibi and insisted they were merely in the wrong place at the wrong time.

Belmonte testified that he was visiting a relative and only went to Gumba’s house to borrow money.
Gumba corroborated Belmonte’s version, while Costales later surrendered upon learning of an arrest warrant.

It found Belmonte, Gumba, and Costales guilty beyond reasonable doubt for illegal sale and related acts under RA 9165.
The RTC’s ruling was based on the comprehensive evidence presented, including the chain of custody and witness testimonies that pointed to a concerted action (conspiracy) among the accused.

The Court of Appeals (CA) later affirmed the RTC ruling, addressing the concerns raised about chain of custody deviations by emphasizing that the integrity and evidentiary value of the seized items were preserved.

Whether the deviations from the strict prescribed procedures under Section 21, Article II of RA 9165 (such as the absence of DOJ and media representatives during parts of the inventory process) invalidated the chain of custody of the confiscated drugs.

Whether the prosecution established, beyond reasonable doubt, the identity of the buyer and the seller, the object of the transaction, the consideration (payment), and the delivery of the contraband.
Whether the evidence adequately demonstrated a conspiracy among the accused in the commission of the crime.

Whether the conduct and testimony of the apprehending officers (including the identification by Ominga and CaAero) were sufficient to affirm the accused’s involvement in the sale of dangerous drugs.