G.R. No. 250927 - Mario Nisperos Padilla vs. People

Petitioner Mario Nisperos was arrested in a buy-bust operation on June 30, 2015, in Tuguegarao City and charged under Section 5, Article II of RA 9165 for Illegal Sale of Dangerous Drugs.
The Regional Trial Court convicted him on March 13, 2018, sentencing him to life imprisonment and a ₱500,000 fine.
On appeal, the Court of Appeals affirmed with modification (denying parole eligibility), and denied reconsideration on November 7, 2019.
Petitioner filed a Rule 45 petition with the Supreme Court, which treated it as an appeal.

PO1 Michael Turingan acted as poseur-buyer and purchased one sealed sachet containing 0.7603 g of methamphetamine hydrochloride (“shabu”) for ₱3,000.
Immediate arrest followed; buy-bust money and drugs were recovered.
Inventory and photograph of the drug were conducted at the transaction site about 30 minutes after seizure, in the presence of Barangay Captain Taguinod and DOJ representative Gangan (who arrived late).
The sachet was unmarked at seizure and only marked during the delayed inventory. The PDEA crime laboratory confirmed the substance as methamphetamine hydrochloride.

Whether the marking of the seized drugs only at the delayed inventory, instead of immediately upon seizure, violated the chain of custody rule.
Whether the inventory and photographing of seized drugs in a warrantless arrest must be conducted “immediately after seizure” at the place of apprehension or may be done at the nearest police station/office of the apprehending team.
Whether mandatory witnesses must be physically present at the time and place of arrest or simply be “readily available” to witness the subsequent inventory.