G.R. No. 238338 - People vs. Dela Rosa y Empamano

A buy-bust team from the SAID Special Operations Task Group in Makati City was mobilized on April 26, 2014 after receiving a tip regarding a male and a female allegedly peddling illegal drugs along Makati Avenue, Barangay Poblacion, Makati City.
The team coordinated with the Philippine Drug Enforcement Agency (PDEA) and proceeded to the target area with an asset.
During the operation, the asset identified Edgardo Dela Rosa y Empamano @ "Boy" as the seller, who allegedly sold a plastic sachet containing suspected shabu to Police Officer 1 Jojo Valdez, acting as the designated poseur-buyer.
The operation resulted in the simultaneous arrest of Edgardo along with his wife, Criselda Huerto y Docot @ "Cecil," and his brother-in-law, Ronaldo Huerto y Docot.

A search on Edgardo’s person yielded an additional four plastic sachets containing suspected shabu.
After being apprised of their rights, the arrested individuals were brought to the barangay hall, where the seized items were marked, photographed, and inventoried in the presence of Barangay Captain Benhur Cruz.
The confiscated items were subsequently sent to a crime laboratory, where they tested positive for Methamphetamine Hydrochloride.

All three accused-appellants were charged with violating Section 5, Article II of Republic Act No. 9165 (the Comprehensive Dangerous Drugs Act of 2002) for the illegal sale of dangerous drugs.
Additionally, Edgardo was charged with violating Section 11, Article II of RA 9165 for illegal possession of dangerous drugs.
During trial, Edgardo and Criselda denied the charges by asserting that on April 25, 2014, they were at a bingo boutique and were abruptly taken into custody by the police, detained for three days, and allegedly coerced to confess after being presented with seized items.

The Regional Trial Court (RTC) of Makati City, Branch 64, rendered a decision on May 18, 2015, finding the accused guilty beyond reasonable doubt:

All accused-appellants were sentenced to life imprisonment and fined P500,000.00 for illegal sale of dangerous drugs.
Edgardo, for illegal possession of dangerous drugs, received an additional sentence of imprisonment ranging from twelve (12) years and one day to fifteen (15) years and was fined P400,000.00.

The Court of Appeals (CA) affirmed the RTC’s decision in its ruling dated November 29, 2016, emphasizing that non-compliance with the witness requirement under Section 21, Article II of RA 9165 does not automatically void the seizure if the integrity and evidentiary value of the evidence remain preserved.

Whether the failure to secure the presence of all required witnesses (DOJ and media representatives) during the inventory and photographic documentation of the seized items undermined the chain of custody.
Whether such non-compliance, in the absence of justifiable grounds or sufficient demonstration of genuine efforts to secure the witnesses, compromised the integrity and evidentiary value of the seized items.

Whether the prosecution was able to satisfactorily prove that the non-compliance was due to justifiable grounds and that the chain of custody was maintained despite procedural lapses.
Whether the failure to account for every link in the chain of custody renders the corpus delicti unestablished, thereby warranting the acquittal of the accused beyond reasonable doubt.

Whether compromised chain of custody procedures, affecting the integrity of the drug evidence, are sufficient to nullify the evidentiary basis for upholding the conviction of the accused.