G.R. No. 198113 - People vs. Bautista y Sinaon

On September 15, 2003, the Provincial Prosecutor of Bulacan filed separate charges against Ferdinand Bautista y Sinaon for selling and possessing dangerous drugs under Sections 5 and 11, Article II of R.A. 9165.
The charges were filed before the Regional Trial Court of Bulacan under Criminal Cases 3529-M-2003 and 3530-M-2003.

On August 31, 2003, the Chief of Police in Meycauayan, Bulacan, received a phone-in tip that Bautista was involved in selling illegal drugs in Barangay Saluysoy, Meycauayan.
Surveillance was conducted, confirming Bautista’s involvement, which prompted the dispatch of a buy-bust team for the operation.

At about 11:40 p.m. on September 3, 2003, police officers (PO1 Tadeo, Frederick Viesca, Michael Sarangaya, Philip Santos, and Manuel Mendoza) were directed to conduct the operation.
PO1 Tadeo approached Bautista’s house while the rest of the team positioned themselves nearby.
A staged encounter ensued where Tadeo, posing as a buyer, indicated interest in purchasing P300.00 worth of shabu and received a plastic sachet from Bautista, along with three marked bills.

Following the staged transaction, a coordinated signal prompted the team’s backup to rush and arrest Bautista.
During the arrest, Bautista was accompanied by a lady-companion later identified as Ma. Rocel Velasco.
The officers demanded that Bautista reveal the contents of his pockets, which resulted in the discovery of the money received and a sachet of shabu.
PO1 Viesca recovered additional suspect items from Ma. Rocel, including one big plastic sachet and eight small sachets, which were subsequently marked with initials.

At the police station, PO1 Tadeo marked the shabu seized from Bautista, while the seizure from Ma. Rocel was marked by PO1 Viesca at the scene of the arrest.
The marking of items was later coupled with the submission of the evidence for forensic examination, which confirmed the presence of methamphetamine hydrochloride (shabu).
Testimonies revealed that key procedural safeguards, such as the physical inventory and photographing of seized items, were either incompletely performed or not conducted in the required presence of representatives, including media or DOJ, as mandated by law.

Bautista and Ma. Rocel denied the charges, with Bautista offering an alternative account alleging a false arrest linked to a separate incident involving stolen items.
The Regional Trial Court, on August 7, 2009, found Bautista guilty beyond reasonable doubt while acquitting Ma. Rocel due to insufficient proof on her part.
The Court of Appeals later affirmed the RTC Decision with modifications on imposed fines in its decision dated February 22, 2011.

Whether the arresting officers preserved the integrity and evidentiary value of the seized dangerous drugs despite failing to comply with the mandatory procedural safeguards under Section 21 of R.A. 9165 and Section 21(a) of its IRR.
Whether the deviations from the prescribed inventory and photographic procedures—such as conducting the marking of evidence away from the scene and in the absence of required representatives—compromise the chain of custody and the probative value of the evidence.
Whether such non-compliance, absent a justifiable ground, renders the prosecution unable to establish the corpus delicti and, ultimately, the guilt of the accused beyond reasonable doubt.