G.R. No. 229219 - People vs. Lazaro y Flores

On January 7, 2008, accused-appellant Roderick Lazaro y Flores was charged with violating Section 5, Article II of Republic Act (R.A.) No. 9165 (the Comprehensive Dangerous Drugs Act of 2002) for the alleged illegal sale of dangerous drugs.
The Information alleged that on or about January 4, 2008, in Dagupan City, Lazaro wilfully sold and delivered a heat-sealed plastic sachet containing shabu (methamphetamine hydrochloride) to a customer, in violation of the prescribed law.

A coordinated buy-bust operation was undertaken by a team of police officers—including PO2 Michael C. De Vera, P/Insp. Leo Llamas, P/Insp. Gilbert Ferrer, Senior PO4 Alex Corpuz, PO2 Romulo Lavarias, and PO2 Reynaldo Reside—at the Philippine National Railways (PNR) site in Dagupan City.
The operation involved a confidential asset who introduced a poseur buyer to PO2 De Vera. During the operation, after negotiating a purchase of shabu worth ₱200.00, Lazaro presented a plastic sachet of the allegedly dangerous drug.
Following the pre-arranged signal, the backup team intervened, resulting in Lazaro’s arrest on the spot after PO2 De Vera identified himself and executed a frisk and confiscation of the buy-bust money and the drug item.
Subsequently, Lazaro was brought first for a medical check-up at Region 1 Medical Center and then transferred to Perez Market Site for further processing at the Philippine National Police (PNP) Station. The seized item was finally transported to the PNP Crime Laboratory in Urdaneta City, where forensic examination confirmed its identity as shabu.

A confiscation receipt was prepared at the transaction scene by PO2 De Vera, marking the beginning of the evidence chain.
Although the drug item was marked and later forwarded for laboratory testing, questions arose regarding the full compliance with the mandatory physical inventory and photographic documentation protocols set out in Section 21 of R.A. No. 9165.

Lazaro contended that on January 4, 2008, he was at his residence in the PNR site, Dagupan City, enjoying a drinking session with his friend Julio Viray when four police officers suddenly entered his house and arrested him without explanation.
He claimed that upon being taken to the police station, he was surprised to be charged with the sale of shabu when shown the sachet.
Julio Viray corroborated that during their conversation at Lazaro’s house, two unidentified men forced their way in, restrained Lazaro, and proceeded with his arrest.

At the Regional Trial Court (RTC) of Dagupan City, Branch 42, Lazaro was tried for the crime of illegal sale of dangerous drugs.
The trial court found the evidence—primarily consisting of the physical evidence and the established chain of custody—sufficient to convict Lazaro beyond reasonable doubt.
The RTC rendered a judgment sentencing Lazaro to life imprisonment and imposing a fine of ₱500,000.00, along with an order regarding the disposition of the seized drugs.

The Court of Appeals (CA), in its Decision dated February 9, 2016, affirmed the RTC’s judgment with modification by excluding Lazaro’s eligibility for parole under the Indeterminate Sentence Law.
Despite acknowledging lapses in following the mandated procedure for the physical inventory of the seized item, the CA held that such deviations did not materially affect the evidentiary weight or admissibility of the seized drug, as the overall chain of custody was deemed substantially compliant.

The prosecution’s case heavily relied on the proper chain of custody of the seized shabu, which is critical to proving the drug’s identity and linking it to the sale transaction.
Section 21 of R.A. No. 9165 mandates that immediately after seizure, the apprehending team must physically inventory and photograph the drugs in the presence of the accused (or his representative), a representative from the media, and an elected public official—all of whom must sign the inventory copy.
An amendment through R.A. No. 10640 later reduced the number of required witnesses from three to two; however, since the offense was committed before this amendment, the original requirements applied.
The failure of the arresting officers to conduct a complete inventory and secure the signatures of the mandated witnesses introduced significant doubts regarding the unbroken chain of custody and, by extension, the integrity of the evidence presented.

Lazaro challenged his conviction on the ground that the prosecution failed to justify the procedural lapses—including the incomplete inventory and the absence of the required witnesses—thus breaking the chain of custody.
The central contention was whether the gaps in following Section 21’s mandated procedures impaired the evidentiary value of the seized drug, thereby failing to prove Lazaro’s guilt beyond reasonable doubt.

Whether the prosecution sufficiently established, beyond reasonable doubt, that the illegal sale of dangerous drugs did indeed occur by proving:

The complete elements of the offense, including the identification of the buyer and seller, confirmation of the transaction, and the nature and consideration of the sale.
The integrity and authenticity of the seized drug through a demonstrably unbroken chain of custody, as mandated by law.

Whether the arresting officers’ failure to fully comply with the procedural safeguards outlined in Section 21 of R.A. No. 9165—specifically the lack of a complete physical inventory and the absence of the three required witnesses—constituted a substantial lapse sufficient to raise reasonable doubt as to the identity and integrity of the evidence (the corpus delicti).