G.R. No. 240541 - People vs. Barrion y Silva

On August 10, 2011, at approximately 7:00 p.m., a Special Operation Task Group of the Station Anti-Illegal Drugs successfully implemented a buy-bust operation against Rey Barrion y Silva.
During the operation, police officers apprehended Barrion and recovered one plastic sachet containing a white crystalline substance.
The seized sachet was initially marked at the place of arrest by PO2 Dan Gonzales.
After transport to a police station, the item was re-marked and placed in a larger plastic sachet.

The seized item underwent inventory and was processed in the presence of designated witnesses:

The evidence was subsequently transported to the crime laboratory where testing confirmed the presence of 0.04 gram of methamphetamine hydrochloride (shabu).
The chain of custody procedures were followed by marking, physical inventory, and eventual submission to the laboratory, although there were noted deviations in the witness requirement.

Barrion contended that he was already detained at the police headquarters at the time the prosecution alleged his apprehension during the buy-bust operation.
He further argued that earlier in the day, at approximately 4:00 p.m., he was forcibly stopped while riding a tricycle, questioned about his alleged involvement in shabu transactions, and subsequently taken to the police station.
His version of events directly contradicted the prosecution’s timeline of his arrest, raising issues regarding the identification and integrity of the alleged corpus delicti.

The Regional Trial Court (RTC) of Lipa City, Batangas, Branch 12, in Criminal Case No. 0453-2011, found Barrion guilty beyond reasonable doubt of the crime of Illegal Sale of Dangerous Drugs under Section 5, Article II of Republic Act No. 9165.
The RTC held that the prosecution established all elements of the crime including possession, identity, and integrity of the seized item.
Barrion was sentenced to life imprisonment and ordered to pay a fine of ₱500,000.00.

Barrion appealed the RTC decision to the Court of Appeals (CA), which affirmed the conviction and sentencing.
On ordinary appeal, the Supreme Court was tasked with reviewing the sufficiency of the chain of custody and the fulfillment of the procedural witness requirements during the inventory of the seized evidence.

Whether the integrity and evidentiary value of the seized dangerous drug was compromised due to a deviation from the prescribed chain of custody procedure.

Specifically, whether marking, inventory, and photography were conducted in accordance with the rules.
Whether the absence of a media representative, as required post-amendment of RA 9165 by RA 10640, adversely affected the reliability of the evidence.

Whether the justifications provided by the prosecution for the procedural lapses (particularly the failure to secure the presence of the media representative) are sufficient to preserve the chain of custody and, consequently, the integrity of the corpus delicti.

The issue includes the evaluation of whether genuine and sufficient efforts were made by the apprehending team to secure all required witnesses.
It also examines whether non-compliance due to field conditions can be excused under the saving clause provided in the law.