G.R. No. 212171 - People vs. Dela Cruz

The accused-appellant, Mercury Dela Cruz, alias “Deday,” was charged with the illegal sale of shabu under Sections 5, Article II of Republic Act No. 9165.
The case stemmed from a buy-bust operation conducted by law enforcement, which resulted in the seizure of a small plastic sachet containing a white crystalline substance later confirmed to be Methamphetamine Hydrochloride.

The buy-bust operation was initiated based on information from a confidential informant who introduced the police team to the accused-appellant.
During the operation:

PO1 Reales, along with SPO Batobalonos and PO1 Bullido, engaged the accused in a transaction where the accused exchanged the said substance for two marked P100.00 bills (totaling P200.00).
After the exchange, the accused attempted to evade immediate arrest. However, the arrest was effected shortly after through the issuance of a warrant.
The apprehending officers encountered resistance and a commotion during the arrest, which led to the firing of a warning shot and the arrest of a bystander, Arthur Tabasa Ortega, for obstruction of justice.

The physical evidence—the seized plastic sachet of drug—was handled following the seizure and was later marked and accompanied by a request for laboratory examination.
The chain of custody was documented as follows:

The apprehending team took possession of the item immediately after the transaction.
PO3 Batobalonos marked the seized item at the police station, and the item was forwarded to the Regional Crime Laboratory for analysis.
Forensic Chemist Mutchit G. Salinas issued a chemistry report confirming the presence of Methamphetamine Hydrochloride.

Although the procedural requirements under Section 21 of R.A. No. 9165 were not strictly followed (e.g., physical inventory and photographing at the scene), the officers explained the deviations attributing them to safety concerns during a chaotic arrest.

The court gave full credence to the testimonies of police officers (PO1 Reales, SPO Batobalonos, and PO1 Bullido) whose accounts were detailed, spontaneous, and consistent with one another.
The accused-appellant’s defense, based solely on denial and alibi, failed to undermine the credibility of these testimonies.
Both the Regional Trial Court (RTC) and the Court of Appeals (CA) found that all essential elements for the crime of illegal sale of dangerous drugs were established.

Whether the essential elements of the crime were satisfactorily proven, specifically:

The identification of the buyer and seller, and the object and consideration involved in the transaction; and
The demonstration of delivery of the dangerous drugs in exchange for payment.

Whether the procedural lapses in the inventory and documentation (as provided by Section 21 of R.A. No. 9165) affected the evidentiary value of the seized drug, given that alternative measures were taken to preserve its integrity.

Whether the categorically affirmative testimony and the presumption of regularity in the performance of official duties by law enforcement officers should override the accused-appellant’s claims of a frame-up and improper evidence handling.

Whether the deviations from the strict requirements under Section 21 (such as the location of marking and the absence of an on-scene physical inventory or photographs) are fatal to the prosecution’s case, given that the integrity of the evidence was maintained.