G.R. No. 230721 - People vs. Jimenez y Delgado

A confidential informant reported illegal drug activities involving a person known as “Monik” at Lakeview Homes Subdivision, Putatan, Muntinlupa City, at around 10:00 a.m. on August 20, 2009.
SPO1 Cirilo Zamora, then assigned as an anti-drug operative, received the tip; the Chief of Police, PSSUPT Elmer Jamias, was immediately informed.
PSSUPT Jamias validated the information and instructed SPO1 Brigido CardiAo, the team leader, to conduct a buy-bust operation after coordinating with the Philippine Drug Enforcement Agency (PDEA).

The team prepared the Pre-Operational Report with the participation of PSUPT Eleazar P. Matta and other anti-drug operatives.
SPO1 CardiAo facilitated the operation by providing buy-bust money (₱1,000.00) to SPO1 Zamora, who, acting as the poseur-buyer, marked the bill and documented it by photograph.
The team, in the company of the informant, proceeded to the designated location (Pasong Makipot, near Lakeview Homes) where “Monik” was to be lured.

At approximately 8:15 p.m. on the same day, SPO1 Zamora, accompanied by the informant, waited in a designated shed until “Monik” appeared.
Upon identification, “Monik” was engaged in a scripted transaction: she received the buy-bust money and handed over a transparent plastic sachet containing a white crystalline substance—later marked with her initials “MDJ”.
The operation was recorded in the police blotter; backup officers joined the scene to finalize the arrest process by explaining constitutional rights and subsequently transporting the suspect and the seized items to the police office.

Once at the office, SPO1 Zamora performed an immediate inventory of the evidence by marking, photographing, and documenting the seized sachet and the remaining money.
However, the required witnesses under Section 21 of R.A. No. 9165 (representatives from the media, the Department of Justice (DOJ), and an elected public official) were notably absent, with only two DAPCO employees present during the inventory despite their late arrival.
The absence of these mandated witnesses raised issues regarding the integrity and proper handling of the seized evidence.

Appellant Monica Jimenez y Delgado claimed that on the day of the operation, she was merely alighting from a tricycle to visit her boyfriend and was subsequently accosted by individuals who later identified themselves as law enforcement officers (SPO1 Zamora and PO2 Genova).
She contended that she was taken by surprise, subjected to coercive questioning and even extortion demands, and that these irregular procedures led to the improper chain of custody of the alleged evidence.
Both the Regional Trial Court (RTC), which convicted her, and the Court of Appeals (CA) which affirmed the conviction, were later reassessed by the Supreme Court concerning the procedural anomalies in the chain-of-custody.

Whether the warrantless arrest of the appellant, conducted during the buy-bust operation, amounted to an illegal seizure and a violation of constitutional rights.

Whether the deviations from the mandatory inventory procedures under Section 21 of R.A. No. 9165—specifically, the absence of the DOJ, media, and elected public official during the physical inventory and photographing of the seized items—rendered the evidence inadmissible.

Whether the prosecution was able to prove all the necessary elements of the crime of illegal sale of dangerous drugs beyond reasonable doubt, given the procedural lapses.

Whether the operation, as executed by the police, can be considered a legitimate and legally sanctioned buy-bust entrapment operation.

Whether the procedural lapses, including the broken chain of custody, introduced sufficient doubt to undermine the evidentiary value of the seized drug and money.