G.R. No. 233653 - People vs. Guanzon y Ceneta

The case involves accused Ricardo Guanzon y Ceneta facing charges for illegal sale and illegal possession of dangerous drugs under Sections 5 and 11, Article II of R.A. No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
Two separate criminal cases were filed:

On or about July 28, 2003, in Antipolo City, Guanzon allegedly sold a heat-sealed plastic sachet containing 0.04 gram of a white crystalline substance (later identified as shabu) to a poseur-buyer, PO2 Vandever D. Hernandez.
The transaction involved a payment of ₱200.00, and the substance tested positive for methylamphetamine hydrochloride in laboratory examinations.

On the same day and same location, Guanzon was also charged with possessing a heat-sealed plastic sachet containing 0.01 gram of white crystalline substance.
The substance, similarly, yielded positive laboratory results for methylamphetamine hydrochloride.

On the morning of July 28, 2003, the PNP received information regarding Guanzon allegedly selling dangerous drugs through information from a concerned citizen and the Brgy. Task Force of Mambugan, Antipolo City.
A coordinated operation was planned in conjunction with the Philippine Drug Enforcement Agency (PDEA).

At around 9:00 a.m., the team arrived at the designated location.
PO2 Hernandez approached Guanzon at the specified address, executed the buy-bust signal by lighting a cigarette, and triggered the arrest.
During the operation, confiscation of a plastic sachet (either bought or found on the person) and marked money occurred.

The confiscated items and the bought specimen were processed by the apprehending officers.
The items were marked (specimens “A” and “B”), inventoried, and eventually submitted to the PNP Crime Laboratory where tests confirmed the presence of shabu.

Detailed account of the buy-bust operation, including the roles of the team members.
Testimonies related to the handling, marking, and chain of custody of the seized items.
Emphasis on the procedures like marking and inventorying as required under Section 21 of R.A. No. 9165 (as amended by R.A. No. 10640).

Guanzon contended that on the morning of July 28, 2003, he was at a friend’s house when armed men entered and arrested him under a mistaken identity scenario.
The defense argued that police officers, lacking dangerous drugs on Guanzon, contrived a story to cash in on a buy-bust operation by coercing him to purchase shabu.
The defense emphasized discrepancies and inconsistencies in the testimonies regarding the chain of custody and the inventory/marking of the seized drugs.

The Regional Trial Court (RTC) found Guanzon guilty beyond reasonable doubt and imposed severe penalties for both charges.
The Court of Appeals (CA) affirmed the RTC decision, holding that minor discrepancies in testimonies were peripheral and did not affect the overall chain of custody.
However, the appellate brief raised issues regarding non-compliance with the mandatory procedures for maintaining the integrity and identity of the seized drugs as mandated by Section 21 of R.A. No. 9165 and its IRR.
Central to the controversy is the issue of an unbroken chain of custody, particularly the initial marking, inventory, and photographic documentation of the drugs, which the prosecution failed to adequately establish.

Whether the RTC and the CA erred in convicting Guanzon beyond reasonable doubt despite the alleged non-compliance with Section 21 of R.A. No. 9165 (as amended by R.A. No. 10640) regarding:

The proper custody and disposition of confiscated evidence, particularly the seized drugs.
Establishment of an unbroken chain of custody showing the identity and integrity of the seized drugs despite discrepancies in the handling and marking procedures.

Whether the failure to strictly adhere to the procedural safeguards (marking, inventory, photograph) adversely affects the prosecution’s duty to prove its case beyond reasonable doubt, thereby upholding the presumption of innocence.