G.R. No. 157107 - Alpine Lending Investors vs. Corpuz

The appellant, Babylyn Manansala y Cruz, was charged with two offenses under Republic Act (RA) No. 9165 – one for the illegal sale of methamphetamine hydrochloride (“shabu”) and another for its illegal possession.
The charges arose from two separate criminal cases, where one indictment alleged that on December 8, 2011, the accused sold approximately 0.012 gram of shabu, and the other charged her with possession of approximately 0.023 gram of shabu.

The case was primarily built on the testimony of PO3 John Alfred Taruc, a poseur-buyer involved in a planned buy-bust operation initiated after a confidential informant tipped off the Manila Police District’s DAID-SOTU.
The operation was carefully orchestrated:

The tip came in the morning, specifying a drug deal to be conducted at 6:00 p.m. at the intersection of Taft Avenue and Kalaw Street.
A team was formed under the supervision of PCINSP Robert Casimiro Domingo, with designated roles for PO3 Taruc (as poseur-buyer) and other police officers acting as back-up.
During the operation, the accused was met, identified by an alias, and engaged in the transaction by handing over a small plastic sachet containing shabu in exchange for a marked P1,000.00 bill.

After the exchange, the back-up team was signaled via a pre-arranged signal (removal of a bull cap), leading to the immediate arrest of the accused and the recovery of additional seized items.
A physical inventory was conducted in the presence of a media representative, with PO3 Taruc marking the items and subsequently turning them over to the police for further forensic examination.

The accused denied the allegations, contending that she did not engage in any drug transaction.
According to her testimony, on the day of the operation, she had visited her husband at the Manila City Jail and was later riding a jeepney when five men in civilian attire directed her to alight.
She claimed that she was then taken to the DAID office where police officers allegedly extorted money from her for her release.

The Regional Trial Court (RTC) of Manila, Branch 13, rendered a joint decision on September 8, 2014, convicting the accused beyond reasonable doubt for both the sale and possession of shabu, imposing life imprisonment for the sale and an indeterminate penalty of 12 years, 1 day to 15 years for possession along with monetary fines.
The Court of Appeals (CA) affirmed the RTC’s decision in its February 9, 2016 ruling, giving more credence to the government’s evidence—primarily the testimony of PO3 Taruc—and contending that the chain of custody of the seized drugs had been properly established.

Whether or not the prosecution complied with the Chain of Custody Rule as required by Section 21 of RA 9165 in preserving the integrity of the seized illegal drug.

The issue centered on the failure to secure all mandatory insulating witnesses during the physical inventory of the seized drugs.
The absence of a representative from the Department of Justice (DOJ) and an elected public official raised serious questions about the reliability of the evidence.

Whether the failure to strictly comply with the chain of custody requirements undermined the evidentiary value of the seized drugs and, consequently, whether this failure warrants the acquittal of the accused.

The appellant argued that the gaps in the chain of custody created reasonable doubt about the integrity of the evidence.
The legal issue also involved whether the police could justify non-compliance with the witnessing requirement under circumstances that normally allow time for proper preparation in planned buy-bust operations.