G.R. No. 234151 - People vs. Dela Cruz y Libonao

The accused, Cesar Dela Cruz y Libonao, also known as "Sesi", was charged with violating Section 5, Article II of Republic Act (RA) 9165 (Comprehensive Dangerous Drugs Act of 2002) by allegedly selling a sachet of shabu (methamphetamine hydrochloride).
The incident allegedly occurred on June 6, 2010, in the Municipality of Aparri, Cagayan, during a planned buy-bust operation conducted by the Philippine Drug Enforcement Agency (PDEA).

A confidential informant tipped off PDEA that the accused was engaged in illegal drug transactions at Macanaya, Aparri, leading to the formation of a buy-bust team.
The team, consisting of designated PDEA officers and a poseur buyer (IO2 Vivien A Molina), proceeded from Tuguegarao City to Aparri, with clear pre-arranged signals (e.g., igniting a lighter) to mark the consummation of the transaction.
At approximately 8:30 PM, the team identified and confronted the accused near his residence. During the encounter, the accused handed over a small, heat-sealed, transparent plastic sachet purportedly containing shabu in exchange for PHP1,000.00 (two pieces of PHP500.00).

Following the transaction, PDEA agents apprehended the accused, disarmed him of a fan knife, and recovered the buy-bust money.
The seized plastic sachet was taken to the Aparri Police Station for marking, inventory, and photographing. However, the required presence of the witnesses—namely, a representative from the media, an elected public official, and a representative from the Department of Justice (DOJ)—was not fully complied with at the scene.
The enclosed laboratory examination, conducted at the PNP Regional Crime Laboratory Office in Tuguegarao City, confirmed the presence of methamphetamine hydrochloride in the sachet. A subsequent urine test on the accused also yielded positive results for the dangerous drug.

The defense presented testimony from the accused and his son, CJ Dela Cruz. The son claimed that on the day of the incident, he and his father were engaged in routine family activities, and that the police burst into their home unexpectedly.
The accused further alleged that he was subjected to torture by the PDEA agents to induce him to reveal names of alleged personalities involved in the drug trade.
The defense maintained that the accounts in the Information and the extensive factual matrix of the prosecution were tainted by procedural and evidentiary irregularities.

The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt, emphasizing that the evidence established both the act and the intent of selling shabu.
The Court of Appeals (CA) affirmed the RTC’s decision, dismissing the accused’s defenses, including claims of procedural lapses—particularly regarding compliance with Section 21 of RA 9165—regarding the chain of custody of the seized evidence.
On appeal under Section 13(c) of Rule 124, the Supreme Court’s Second Division later scrutinized the procedural lapses concerning the chain of custody and the presence of the required witnesses during the inventory and photographing of the seized drug.

Whether the prosecution was able to prove beyond reasonable doubt that Cesar Dela Cruz violated Section 5, Article II of RA 9165 by selling shabu.
Whether the existence of the seized drug, as part of the corpus delicti, was sufficiently established, given the lapses in the chain of custody.

Whether the buy-bust team complied with the mandatory procedural requirements under Section 21 of RA 9165, including (a) immediate inventory and photographing of the seized drugs at the place of apprehension, and (b) the presence of three compulsory witnesses (accused or his representative, an elected official, a DOJ or media representative).
Whether the failure to secure the presence of all required witnesses and to conduct the inventory at the scene compromised the evidentiary value and integrity of the seized drugs.

Whether the lapses in the chain of custody and procedural non-compliance should negate the presumption of regularity in the conduct of law enforcement.
Whether such lapses reasonably create doubt regarding the reliability of the evidence and, therefore, mandate an acquittal due to failure to overcome the presumption of innocence.