G.R. No. 243578 - People vs. Delina y Lim

The case arose from an Information dated April 15, 2014, wherein Bryan DeliAa y Lim was indicted for the illegal sale of dangerous drugs under Section 5, Article II of Republic Act No. 9165 (the "Comprehensive Dangerous Drugs Act of 2002").
During his arraignment, DeliAa entered a not guilty plea, prompting trial proceedings.

The investigation was initiated after reports of DeliAa’s involvement in illegal drug activities were received at the Calatrava Municipal Police Station.
PO2 Dwight Fajardo, a member of the Calatrava Municipal Police, reported that several known drug personalities visited DeliAa’s residence in Barangay Suba, prompting further surveillance.
On April 14, 2014, an asset informed the police that DeliAa was selling drugs; this led to instructions for the asset to buy shabu valued at P400.00, thereby confirming the illegal transaction.
Chief of Police Mark Angelo P. Junco, after coordinating with a buy-bust team and obtaining a go-signal from the Philippine Drug Enforcement Agency (PDEA), proceeded to execute a buy-bust operation.
During the operation, the asset conducted the purchase by handing marked money (two P100 bills and one P200 bill) to DeliAa, who in turn handed over two sachets of a white crystalline substance.
DeliAa was promptly arrested by officers, and both the cash and the seized drug specimens were taken into custody.

The seized money and drug specimens were inventoried and photographed at the police station in the presence of representatives from the Department of Justice (DOJ), the media, and barangay officials.
The specimens were turned over to the PNP Crime Laboratory at Camp Alfredo Montelibano, Sr. in Bacolod City for examination.
Forensic Chemist PCI Puentespina of the PNP Crime Laboratory conducted tests, issuing a report (Chemistry Report No. D-120-2014) that confirmed the presence of methamphetamine hydrochloride.
Notably, certain procedural lapses were observed in the chain of custody, including delays and deviations in marking and inventory procedures immediately at the scene.

The prosecution’s version was supported by the testimonies of police officers such as Fajardo, who detailed the sequence of events during the buy-bust operation, including the involvement of a confidential asset designated as the poseur-buyer.
DeliAa, on the other hand, denied the charges and claimed he was framed. He alleged that on the day of the arrest, he was engaged in personal activities (hanging his girlfriend’s clothes) when police officers suddenly apprehended him without prior explanation.
The prosecution failed to present the confidential asset (poseur-buyer) during trial, a point that was later underscored by DeliAa as a critical lapse affecting the credibility of the evidence.

The Regional Trial Court (RTC) of San Carlos City, Negros Occidental, Branch 59, in its October 17, 2016 Decision, found DeliAa guilty beyond reasonable doubt based on the presented evidence and sentenced him to life imprisonment along with a fine.
The Court of Appeals in Cebu City affirmed the RTC’s decision in its April 12, 2018 Decision, which became the subject of this appeal.

Whether the failure of the buy-bust team to strictly comply with the chain of custody requirements under Section 21 of RA 9165, particularly in marking and photographing the seized drug specimens immediately at the scene, compromised the integrity of the evidence.
Whether the absence of the poseur-buyer’s testimony, who was the sole witness to the actual illegal drug transaction, undermined the prosecution’s evidence beyond reasonable doubt.
Whether the lapses in the procedures—such as improper handling and incomplete documentation of the chain of custody—resulted in the violation of the accused’s right to due process under the constitutional requirement for clear and complete judicial reasoning.