G.R. No. 236325 - Commissioner of Internal Revenue vs. Filminera Resources Corp.

On January 20, 2005, in Tuguegarao City, Cagayan, accused Hermanos Constantino, Jr. (also known as aJojit) was charged with the illegal sale of methamphetamine hydrochloride (shabu) under Republic Act No. 9165.
The charge arose from an alleged transaction during which Constantino was accused of selling two heat‐sealed transparent plastic sachets containing 0.14 gram of shabu to a member of the PNP, who acted as a poseur-buyer.
The sale was ostensibly conducted without a permit or legal authority to sell, transport, deliver, or distribute dangerous drugs.

The operation was initiated upon receipt of a tip from a confidential informant, leading Police Superintendent Mariano Rodriguez to form a buy-bust team.
Team members included Senior Police Officer (SPO2) Noel Taguiam, SPO2 Alexander Tamang, SPO1 Arthur Blaquera, PO3 Edwin Hernandez, and PO3 Rolando Domingo (designated as the poseur-buyer).
At approximately 2:00 PM, the informant’s tip led the team to Lt. Constantino’s location, and the buy-bust money (a total of P1,000 comprising one P500 bill and five P100 bills) was prepared and documented with serial numbers.

At around 8:00 PM on the same day, the buy-bust team executed their plan at Reynovilla St., Caritan Centro, Tuguegarao City, where Constantino was detected on board a tricycle.
PO3 Domingo, acting as the poseur-buyer, identified Constantino and engaged him in a conversation that culminated in the alleged sale.
Constantino exchanged the two plastic sachets containing the shabu for the marked money, and a pre-arranged signal (the turning of PO3 Domingo’s cap backwards) indicated the consummation of the transaction.
The buy-bust team immediately arrested Constantino upon completion of the deal, and the seized money and drugs were recovered and documented shortly thereafter.

After the arrest, Constantino was taken to the police station, where the recovered drugs and money were submitted to the investigating officer, SPO2 Tamang.
The sachets were marked with specific initials (aA-1a, aA-2a, and NBT) but inconsistencies arose regarding who applied the markings and when.
Testimonies revealed that PO3 Domingo stated the marking was done by SPO2 Tamang, while PO3 Hernandez implicated SPO2 Taguiam and P/SInsp. Tulauan later attributed similar markings to SPO3 Nelson B. Tamaray upon receipt of the drugs at the Crime Laboratory.
These multiple and conflicting accounts created confusion over whether the sachets presented in court were indeed the very items seized during the buy-bust.

At arraignment on July 8, 2005, Constantino pleaded not guilty and later asserted that he was framed.
His defense narrative contended that he had been enjoying a joyride with a friend prior to being accosted by individuals masquerading as police officers.
According to Constantino, he was forcibly detained, searched, and subsequently taken to the police station where evidence was fabricated against him.
He denied participating in a drug sale, attributing the incident to a set-up that did not match the detailed police account of the buy-bust operation.

The Regional Trial Court (RTC), Branch 5 of Tuguegarao City, convicted Constantino on April 15, 2008, sentencing him to life imprisonment and imposing a fine of P500,000.00.
The court rejected key defense arguments concerning insufficient details in the buy-bust operation, non-compliance with inventory and photographic requirements, and the alleged failure to establish a reliable chain of custody.
The Court of Appeals (CA) later affirmed the RTC’s decision on July 29, 2011, upholding the conviction by emphasizing the overall consistency of the prosecution witnesses against the weak and uncorroborated defense version.
During the appellate proceedings, emphasis was placed on the presumption of regularity in the performance of official duties by the apprehending officers and the significance of the recorded transaction.

Central to the case was the establishment of the chain of custody for the seized shabu, which was partly dependent on the accurate and timely marking of the evidence.
The conflicting testimonies regarding who marked the sachets (be it SPO2 Tamang, SPO2 Taguiam, or SPO3 Nelson B. Tamaray) raised doubts about whether the evidence had been properly preserved.
The lapse in immediately marking the items upon seizure was identified as a critical procedural flaw that jeopardized the integrity of the chain of custody.
Given these inconsistencies, the prosecution’s evidence could be questioned regarding the authenticity and continuity of the seized drugs from seizure to presentation in court.

The Supreme Court scrutinized the conflicting evidence regarding the marking of the sachets and the subsequent chain of custody.
The Court found that the inconsistent accounts of the marking process had broken the crucial link needed to ensure the integrity of the evidence.
The failure to clearly corroborate the chain of custody rendered the prosecution’s case fatally flawed.
As a result, despite the prosecution’s narrative of a bona fide buy-bust operation, the evidence did not satisfy the requirement of proving guilt beyond reasonable doubt.
Consequently, the Supreme Court granted Constantino’s appeal, reversed the lower courts’ decisions, and ordered his immediate release.

Whether the chain of custody of the seized shabu was properly established and maintained from the moment of seizure to its presentation in court.

The issue centered on the inconsistent and conflicting testimonies regarding the marking of the plastic sachets.

Whether the inconsistencies in the accounts of who marked the sachets (SPO2 Tamang, SPO2 Taguiam, or SPO3 Nelson B. Tamaray) compromised the integrity of the evidence.
Whether the prosecution was able to prove, beyond reasonable doubt, the occurrence of an illegal drug sale as part of the buy-bust operation.
Whether the procedural lapses—such as the alleged non-compliance with the inventory and immediate photographic requirements during the seizure—had a prejudicial effect on the integrity of the evidence.
Whether the defense’s narrative of being framed provided a sufficient basis for reasonable doubt in light of the evidence discrepancies.