G.R. No. 212192 - People vs. Abdula y Mama

A buy-bust operation was conducted on October 24, 2007, in Manila following a tip from a confidential informant.
The informant reported that a suspect known as “Mike” was peddling dangerous drugs, prompting immediate action by law enforcement.
SPO3 Leo Letrodo of the PDEA, along with IO1 Liwanag B. Sandaan and PO2 Anatomy B. Gabona, were assigned to execute the operation.

The operation was meticulously planned with the informant placing an order for shabu (methamphetamine hydrochloride) and designating a meeting at ACE Hardware store at SM City Manila.
The team prepared a “boodle” of money, which comprised a genuine bill overlaid with a fake one, to simulate a transaction.
Pre-arranged signals were set: for instance, IO1 Sandaan’s scratching of her head served as the cue for the team to initiate the arrest.
Upon the suspect’s arrival with a small blue plastic bag, the informant introduced IO1 Sandaan as the buyer, and an exchange ensued—money was given in return for a bag purportedly containing the drugs hidden within slippers.

After the transaction, PO2 Gabona arrested “Mike” and recovered the marked money.
The seized items—comprising a marked plastic bag, a pair of blue slippers, and three separate clear plastic sachets (purported to contain shabu)—were subsequently inventoried in the presence of Barangay Chairperson Dr. Salvacion Pomperada.
IO1 Sandaan executed her duty by marking the specimens with her initials, preparing requests for laboratory examination and drug testing, and ensuring that the seized items were documented for chain of custody.
Photographic evidence was taken; however, significant gaps were later noted—while images of the plastic bag and slippers existed, there was no image of the sachets supposedly containing the dangerous drugs.

The prosecution’s version, supported by multiple witness testimonies and the documented inventory, established that the accused-appellant, Metokur Abdula, engaged in the illegal sale of dangerous drugs.
The accused-appellant contended that he was at the mall buying school supplies with his children when he was suddenly apprehended. He claimed that the arrest was irregular and that he did not engage in any drug sale transactions.
His son, Najib Abdulla, provided testimony that corroborated the sudden and unexplained nature of the father’s arrest, though his account differed in timing and details from that of his father.

Questions arose regarding the irregularities in the arrest process, including allegations of extortion by law enforcers demanding money after the apprehension.
The absence of key members (e.g., representatives from the DOJ or media) during critical stages such as the marking and inventory of evidence cast further doubt on the integrity of the chain of custody.
The failure to capture photographic evidence of the sachets contributed to the ambiguity as to whether the dangerous drugs recovered were indeed the items seized from the accused-appellant.

Whether the law enforcement team complied with the statutory and procedural requirements governing the handling and inventory of dangerous drugs during a buy-bust operation.
Whether the gaps in the chain of custody—specifically the absence of photographs of the actual drug sachets—compromise the integrity and evidentiary value of the corpus delicti.
Whether the procedural lapses, including non-observance of mandated inventory procedures and irregularities in the conduct of the buy-bust operation, resulted in a violation of the accused-appellant’s constitutional rights, particularly his presumption of innocence.
Whether the defense’s claims of frame-up and extortion, despite being commonly raised in such cases, were substantiated with clear and convincing evidence to warrant a reversal of conviction.