G.R. No. 50173 - Castro vs. Mendoza

Accused-appellants Gerald Flores y Alagdon, Harrold Francisco y Gabat a.k.a. "Punonoy," and Louie Truelen y Grezola were charged in Criminal Case No. R-QZN-16-14780-CR for violation of Section 5 (sale, trading, administration, dispensation, delivery, distribution, transportation of dangerous drugs) of R.A. No. 9165 (Comprehensive Dangerous Drugs Act of 2002) for an alleged buy-bust operation involving 0.10 gram of methamphetamine hydrochloride (shabu).
Accused-appellant Louie Truelen was also charged in Criminal Case No. R-QZN-16-14784-CR for violation of Section 13 of R.A. No. 9165 for possession of 0.05 gram of methamphetamine hydrochloride during a social gathering.

On December 12, 2016, based on information from a confidential informant, the police conducted a buy-bust operation in Quezon City around 9:00 p.m.
Police Officers PO1 Emmer Amar acted as the poseur-buyers, PO1 Lesly Allan Corpuz and PO1 Sherwin Bumagat as perimeter back-up.
The transaction involved the use of a marked P500 bill to purchase a heat-sealed plastic sachet containing white crystalline substance (shabu) from accused-appellants.
Additional sachets of shabu were confiscated from the accused-appellants during frisking.

The police officers executed a Joint Affidavit of Apprehension detailing the operation, custody, and inventory of the seized drugs.
The inventory and marking of the confiscated items were conducted at the police station, witnessed by a media representative (Jun Tobias) and a barangay kagawad (Nelson N. Dela Cruz).
The Chemistry Report confirmed the seized substances as methamphetamine hydrochloride.
Chain of Custody Forms and Inventory of Seized/Confiscated Item/Property Form were duly accomplished.

Accused-appellants denied the charges, claiming illegal arrest, physical abuse, and absence of lawful seizure during the operation.
They also testified about being subjected to drug tests and transferred between police precincts.

The RTC found the accused-appellants guilty beyond reasonable doubt of illegal sale and possession of dangerous drugs.
The court upheld the legitimacy of the buy-bust operation despite lack of coordination with Philippine Drug Enforcement Agency (PDEA).
Sentence included life imprisonment and fines ranging from P400,000 to P500,000.

The CA affirmed and slightly modified the RTC decision, sentencing accused sufficiently for the crimes charged.
The CA held the prosecution had proved all elements of the offense and chain of custody.

The prosecution and defense both waived filing supplemental briefs.
The Supreme Court reviewed the evidence and procedural compliance concerning chain of custody and inventory procedures.

Whether the presumption of regularity applies to the police officers’ performance of duties in the buy-bust operation and inventory, allowing reliance on police testimonies and the chain of custody despite procedural deficiencies.

Whether the prosecution sufficiently complied with Section 21, paragraph 1 of R.A. No. 9165 (as amended), particularly the requirements for immediate inventory, presence of accused or representative, presence of insulating witnesses (media representative, elected public official, and DOJ / prosecution or media representative), and documentary proof of their identities and presence.

Whether the chain of custody of the seized drugs was properly established without reasonable doubt given discrepancies in inventory timing, questionable presence and identification of insulating witnesses, and delays in their arrival.

Whether the accused-appellants’ constitutional right to presumption of innocence was violated by relying on the presumption of regularity despite weak or missing evidence on critical links of chain of custody.

The effect of the death of accused-appellant Louie Truelen on his criminal liability and pending cases.