G.R. No. 107382 - Associated Bank vs. Court of Appeals

The accused, Christopher Ilagan y Baaa, also known as “Weng,” was 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 (marijuana).
The charge stems from the Information stating that on September 11, 2012, at about 5:20 in the afternoon, at Poblacion 3, Municipality of San Jose, Batangas, the accused allegedly sold, delivered, and gave away three heat-sealed transparent sachets containing dried marijuana fruiting tops (totaling 3.20 grams) without lawful authority.

A civilian asset reported to local police officials (SPO1 Flores and PO2 Mitra) that a person known as “Weng,” a helper at the Juennesse Flower Shop, was engaged in selling marijuana.
The report led police to coordinate a buy-bust operation after informing their superior and, subsequently, the PDEA was notified though with delays due to communication challenges.

The team, comprising SPO1 Flores, PO2 Mitra, and the civilian asset, proceeded to the flower shop in a Toyota Corolla.
Upon arrival, the asset identified “Weng” inside the shop; at the signal of a pre-arranged cue (a scratch on the nape by PO2 Mitra), the operation was executed.
During the transaction, PO2 Mitra exchanged two one hundred peso bills for the three sachets of suspected marijuana which “Weng” produced from his right pocket.

Immediately following the transaction, the police arrested the accused and secured his rights by informing him of them.
After the arrest, the item inventory was conducted at the barangay hall of Brgy. 3 in the presence of a barangay captain and a media representative, where items were marked (with labels “ROM-1” to “ROM-5”) and photographs were taken.
Notably, the marking, inventory, and photography took place at the barangay hall rather than at the place of arrest, and the three-witness requirement was not fully complied with at the time of seizure.

Christopher Ilagan claimed he was working as a flower arranger at the Jeunnesse Flower Shop at the time of the incident.
According to his version, police officers in civilian clothes and uniform forcibly apprehended him without properly explaining or justifying the arrest.

The accused insisted that he did not possess any illegal drugs, contending that the marijuana allegedly listed in the seizure document was never his.
He contested the procedure followed by the police, particularly noting that he was forced to sign a Receipt of Property Seized, which he refused to endorse due to discrepancies.

On January 23, 2014, the RTC of Batangas City (Branch 84) rendered a judgment finding the accused guilty beyond reasonable doubt and sentenced him to life imprisonment along with a fine of ₱500,000.
The RTC held that the buy-bust operation was a legally effective procedure and that the evidentiary chain-of-custody, despite procedural lapses, sufficed to establish guilt.

On January 26, 2016, the CA affirmed the RTC’s conviction, dismissing the accused’s appeal and highlighting minor inconsistencies in witness testimonies that did not affect the central facts of the crime.

Under Section 21 of RA 9165, the law mandates that seized items must be physically inventoried and photographed immediately at the place of seizure, in the presence of the accused (or his representative), a media representative, a DOJ representative, and an elected public official.

The inventory and marking of the seized items were executed at the barangay hall instead of at the place of apprehension.
Only two witnesses (the barangay captain and a media representative) were present during the inventory, thereby failing to meet the statutory requirement of three witnesses at the time of seizure.

Whether the prosecution was able to prove, beyond reasonable doubt, that the accused committed the crime of illegal sale of dangerous drugs in light of the procedural lapses.
Whether the deviations from the mandated chain-of-custody procedures, particularly the failure to conduct the inventory at the seizure scene with the full complement of required witnesses, undermined the integrity of the evidence.