G.R. No. 214536 - Coronel y Santillan vs. People

The accused-appellant, Salim Ismael y Radang, was charged with violations of Sections 5 and 11, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) for illegal sale and possession of methamphetamine hydrochloride (shabu).
There were twin criminal cases: Case No. 5021 (19952) for illegal sale, and Case No. 5022 (19953) for illegal possession of dangerous drugs.

Criminal Case No. 5021 alleged that on or about August 25, 2003, in Zamboanga City, Salim sold one small transparent plastic pack containing shabu to SPO1 Roberto Alberto Santiago, a police officer acting as a poseur buyer.
Criminal Case No. 5022 alleged that on the same date and place, Salim was found possessing two small heat-sealed transparent plastic packs containing shabu, which were in his custody and control.

A confidential informant tipped off SPO4 Menardo Araneta about Salim’s illegal drug selling at Barangay Talabaan near the Muslim cemetery in Zamboanga City.
A buy-bust team was formed, with SPO1 Santiago as the poseur buyer. SPO1 Santiago approached Salim and transacted a sale for P100 marked money.
After the sale, SPO1 Rodriguez arrested Salim and conducted a body search, retrieving the marked money and two more plastic sachets containing white crystalline substance wrapped in a cigarette paper from Salim's left front pocket.
Salim was brought to the police station, and seized items were turned over to PO3 Floro Napalcruz (Desk Officer), who then turned them over to PO2 Rodolfo Dagalea Tan (Duty Investigator).
PO2 Tan marked the items with his initials and requested laboratory examination. The PNP Regional Crime Laboratory’s Chemistry Report confirmed that the substances were methamphetamine hydrochloride.

Salim denied selling or possessing any shabu. He stated that on the day of arrest, he was on his way home after buying cellphone load and was arrested by men in civilian clothes claiming to be police officers about 160 meters from the Muslim cemetery.
Salim claimed no drugs were found on him during the search and that the police only took his money.
He denied meeting the arresting officers prior to the incident.

On August 31, 2010, RTC Branch 12, Zamboanga City, convicted Salim beyond reasonable doubt for both illegal sale and possession of shabu.
He was sentenced to life imprisonment and P500,000 fine for illegal sale; and 12 years and 1 day to 15 years imprisonment and P300,000 fine for illegal possession.
The RTC credited the testimonies of SPO1 Santiago and SPO1 Rodriguez and dismissed the defense’s frame-up claim due to lack of clear and convincing evidence.

On June 14, 2013, CA affirmed the RTC’s judgment in toto.
The CA held that the prosecution established all elements of the offenses and gave full credence to the police officers’ testimonies.
The CA also found the integrity and evidentiary value of the seized drugs properly preserved.

Establish the identity of the seized drugs beyond reasonable doubt; and
Comply with the strict requirements of Section 21, RA 9165 regarding the chain of custody.

Whether the prosecution sufficiently established the crime of illegal sale and illegal possession of dangerous drugs beyond reasonable doubt.
Whether the prosecution complied with the strict chain of custody requirements under Section 21, Article II of RA 9165 and its Implementing Rules and Regulations.
Whether the seized drugs’ identity and integrity were properly preserved to form the corpus delicti of the offense.