G.R. No. 237428 - Republic vs. Sereno

On October 1, 2002, Ramil Doria Dahil and Rommel Castro were charged in three separate Informations before the Regional Trial Court (RTC):

Criminal Case No. DC 02-376: Dahil and Castro charged with illegal sale of marijuana in violation of Section 5, Article II of Republic Act (R.A.) No. 9165. The information alleged the sale of 26.8098 grams of marijuana on September 29, 2002, in Angeles City.
Criminal Case No. DC 02-377: Dahil charged with possession of 20.6642 grams of marijuana in violation of Section 11, Article II of R.A. No. 9165.
Criminal Case No. DC 02-378: Castro charged with possession of 130.8286 grams of marijuana in violation of Section 11, Article II of R.A. No. 9165.

Castro was arraigned and pleaded not guilty on November 14, 2002.
Dahil’s arraignment was deferred due to a motion for reinvestigation but was eventually arraigned on August 6, 2009—pleading not guilty.
Trial commenced in RTC where the prosecution presented Police Officers PO2 Arieltino Corpuz and SPO1 Eliseo Licu as witnesses.

PDEA Region 3 agents conducted weeks-long surveillance based on information about marijuana trafficking in TB Pavilion, Marisol Subdivision, Angeles City.
On September 29, 2002, a buy-bust operation was executed by a team led by Sergeant Juanito dela Cruz. PO2 Corpuz acted as the poseur-buyer.
PO2 Corpuz and an informant approached Dahil’s residence, where Dahil and Castro were present.
PO2 Corpuz introduced himself as buyer, Dahil offered six (6) tea bags of marijuana worth P200, and Castro received marked bills.
Upon confirmation of sale, the team arrested Dahil and Castro and confiscated marijuana items:

Seized items were brought to the PDEA office, marked, inventoried, and then submitted to the Philippine National Police (PNP) Crime Laboratory for chemical examination, which tested positive for marijuana.
The prosecution and defense stipulated essential points regarding the forensic chemist’s laboratory examination, including the absence of a personal knowledge about the source and chain of custody.

Dahil claimed abduction from his residence by unknown men and denial of knowledge of alias “Buddya.”
Castro claimed presence in a public place playing chess and denial of knowledge of “Boy” at Hardian Extension before being forcibly taken and charged.

Found Dahil and Castro guilty beyond reasonable doubt of illegal sale and possession of marijuana.
Imposed life imprisonment and fines for illegal sale; 12 years and 1 day to 14 years reclusion temporal and fines for possession.
Held that all elements were proven and rejected defense claim of frame-up.
Photocopies of the marked money admitted as evidence despite loss of originals.

Appellants raised issue on the substantial compliance with the chain of custody required under R.A. No. 9165.
Supreme Court granted appeal upon meticulous examination of facts and procedural history.

Whether the law enforcement officers substantially complied with the chain of custody requirements under R.A. No. 9165 in handling the seized marijuana.

Whether the prosecution sufficiently proved the identity and integrity of the seized substances to establish the corpus delicti of illegal sale and possession of dangerous drugs.