G.R. No. 218126 - People vs. Miranda

The appellant, Danilo García Miranda, was indicted by two separate informations on April 15, 2010 in ParaAaque City for:

Violation of Section 5 of Republic Act No. 9165 (illegal sale of dangerous drugs)
Violation of Section 11 of the same statute (illegal possession of dangerous drugs)

The charges arose from an alleged buy-bust operation where the appellant was accused of selling a small, heat-sealed plastic sachet weighing 0.14 gram, and later, his possession of a sachet weighing 0.24 gram, both testing positive for methylamphetamine hydrochloride.

Law enforcement officers, including PO3 Fernan Acbang (designated as the poseur-buyer) and PO2 Domingo Julaton III (as back-up), executed the operation.
The operation was coordinated following a tip-off about the appellant selling illegal drugs; marked money was used, and the transaction took place on Bagong Silang Street in Barangay Baclaran.
After the transaction, officers detained the appellant at his house, conducted an inventory of the recovered sachets, and photographed both the suspect and the evidence.
A barangay tanod (Romero Cantojas) was present during the inventory, though his role did not comply with the full set of required witnesses as mandated by law.

Testimonies of the arresting officers about the conduct of the buy-bust operation and the physical inventory at the appellant’s house.
Documentary evidence (e.g., pre-operation forms, coordination forms, the inventory receipt, laboratory examination reports, and spot reports) establishing the chain-of-custody from seizure to submission in court.

The forensic chemist, Insp. Richard Mangalip, conducted the laboratory examination and produced a report confirming that both sachets contained methylamphetamine hydrochloride.
However, by stipulation, his testimony regarding the handling of the specimen was dispensed with, leaving gaps in the chain-of-custody records prior to and after the laboratory analysis.

The appellant denied any involvement in the sale or possession of shabu, contending that:

The police officers unlawfully and abruptly entered his house without a valid search warrant.
The evidence was planted, and there was inadequate procedural observance during the arrest and inventory process.

Witnesses, including members of the appellant’s family and other individuals present at the scene, testified that the entry and subsequent inventory were conducted in a manner inconsistent with the prescribed legal procedures.
The defense raised the issue of non-compliance with the mandatory inventory protocol under Section 21 of RA 9165, specifically the absence of the required independent witnesses (a media representative, a DOJ representative, and an elected public official).

The trial court, Branch 259 of ParaAaque City RTC, after an amended decision dated April 16, 2012, found the appellant guilty on both charges:

Life imprisonment and a fine of Php 500,000 for violation of Section 5.
Imprisonment of twelve (12) years and one (1) day to seventeen (17) years and four (4) months plus a fine of Php 300,000 for violation of Section 11.

The appellant’s subsequent motion for reconsideration was denied.
The Court of Appeals affirmed the trial court’s ruling on July 25, 2014 and denied another motion for reconsideration on October 24, 2014, thereby upholding the conviction.

On appeal, issues centered on the integrity of the chain-of-custody and the absence of the legally required witnesses during the inventory.
The defense argued that such lapses created reasonable doubt as to the identity and integrity of the seized drug items, thereby undermining the prosecution’s evidence.
Cited precedents emphasized that strict compliance with procedural safeguards was essential in drug cases given the ease of tampering or planting evidence.

Whether the prosecution was able to prove beyond reasonable doubt the appellant’s guilt in the crimes of illegal sale and illegal possession of dangerous drugs.

Whether the repeated breaches in the chain-of-custody—specifically, the failure to secure the presence of the three mandated witnesses during the inventory and the absence of complete testimony concerning the forensic handling—undermine the probative value of the evidence.

Whether the justifications provided by the law enforcement officers (regarding the absence of required witnesses due to time constraints and operational exigencies) are acceptable under RA 9165 and its implementing rules.