Facts:

The case involves Malik Manalao y Alauya, who was charged with violating Sections 5 and 11, Article II of Republic Act No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002. The events took place on June 15, 2004, in Purok 6, Barangay Poblacion, Tubod, Lanao del Norte, Philippines. Manalao was accused of selling one deck of Methamphetamine Hydrochloride (shabu) weighing approximately 0.1 gram to a police poseur-buyer for P200.00, and of possessing three additional decks of shabu weighing around 0.4 grams.

Upon his arraignment on August 9, 2004, Manalao pleaded not guilty to both charges. The prosecution's case was built around the testimonies of Senior Police Inspector Mary Leocy Jabonillo Mag-abo, a forensic chemist, and Police Officer 1 (PO1) Michael Solarta, who participated in the buy-bust operation. The operation was initiated after reports of Manalao's drug activities surfaced. On the night of June 15, 2004, the police team, posing as customer...

Facts:

1. Background of the Case: Malik Manalao y Alauya (Manalao) was charged with violating Sections 5 and 11, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). The charges stemmed from two separate incidents on June 15, 2004, in Tubod, Lanao del Norte, involving the sale and possession of methamphetamine hydrochloride (shabu).
2. Criminal Charges:
   • Criminal Case No. 056-07-2004: Manalao was accused of selling one deck of shabu weighing 0.1 gram for P200.00 to a police poseur-buyer.
   • Criminal Case No. 057-07-2004: Manalao was accused of possessing three decks of shabu weighing 0.4 grams.
3. Buy-Bust Operation: A buy-bust operation was conducted by the Philippine National Police (PNP) based on reports of Manalao’s drug-pushing activities. PO1 Michael Solarta, part of the buy-bust team, testified that Manalao handed shabu to a civilian agent in exchange for marked money. Upon arrest, Manalao was found in possession of shabu and the buy-bust money.
4. Defense: Manalao claimed he was arrested on June 9, 2004, not June 15, 2004. He testified that he was wrongly accused and that the evidence recovered from him was planted.
5. Trial Court Decision: The Regional Trial Court (RTC) found Manalao guilty of both charges and sentenced him to life imprisonment and fines. The Court of Appeals (CA) affirmed the RTC’s decision.

Issue:

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Ruling:

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Ratio:

1. Illegal Sale of Dangerous Drugs:
   • The elements of illegal sale (identity of buyer and seller, object, consideration, and delivery) were established through the testimony of PO1 Solarta and the recovery of marked money.
   • The non-presentation of the civilian poseur-buyer was not fatal to the prosecution’s case, as PO1 Solarta sufficiently testified to the transaction.
2. Chain of Custody:
   • While there was non-compliance with Section 21 of RA 9165 (inventory and photographing of seized items), the integrity and evidentiary value of the seized drugs were preserved.
   • The prosecution proved the links in the chain of custody through the testimony of the forensic chemist and the marking of the seized items.
3. Illegal Possession of Dangerous Drugs:
   • The elements of illegal possession (possession of prohibited drugs, lack of legal authority, and conscious possession) were established through the recovery of shabu from Manalao during a lawful search incident to arrest.
   • Manalao’s defense of denial was rejected as it was unsupported by evidence.