G.R. No. 244287 - People vs. Padua y Cequena

On December 17, 2014, the Binangonan Police Station planned a buy-bust operation targeting Jemuel Padua based on intelligence and surveillance reports that he was selling illegal drugs at Barangay Libis, Binangonan, Rizal.
A designated police officer, PO1 Zaldy Manigbas, was assigned as the poseur-buyer while other officers served as back-up. An informant accompanied the team and introduced PO1 Manigbas to Jemuel as his co-worker.
The informant indicated that a transaction for shabu (methamphetamine hydrochloride) would occur, prompting PO1 Manigbas to present boodle money—two P100.00 bills marked "ZBM-1" and "ZBM-2"—to Jemuel.

Upon receiving the boodle money, Jemuel handed a plastic sachet containing a white crystalline substance to PO1 Manigbas.
PO1 Manigbas executed a pre-arranged signal indicating the consummation of the transaction, identified himself as a police officer, and noted that Jemuel resisted arrest.
Fellow law enforcers immediately assisted in frisking and arresting Jemuel. During the process, two additional plastic sachets and two strips of aluminum foil were recovered.
The recovered items were systematically marked:

An inventory of the seized items was completed in the presence of a barangay official, followed by photographs at the police station and subsequent submission to forensic chemist P/Sr. Insp. Maria Pia Moskito for examination.
Forensic tests confirmed that the substances contained in the three sachets tested positive for methamphetamine hydrochloride.

The authority charged Jemuel with Illegal Sale of Dangerous Drugs (Criminal Case No. 14-668) and Illegal Possession of Dangerous Drugs (Criminal Case No. 14-669), with specific details on the weight and markings of the recovered substances.
The criminal charges alleged willful, unlawful, and knowing sale and possession of shabu in violation of Sections 5 and 11, Article II of Republic Act (RA) No. 9165.

He was on his way home riding a motorcycle when he was ambushed by four men.
These men forcibly blocked his path, brandished firearms, and compelled him to enter a house where unknown items were present.
Photographs were taken in his presence with the items, and he was physically assaulted before being taken to the police station.

On February 26, 2017, the Regional Trial Court (RTC) convicted Jemuel of the offenses charged.
The Court of Appeals (CA) affirmed the RTC’s conviction on September 19, 2018, emphasizing that the prosecution had established both the elements of the crimes and an unbroken chain of custody of the dangerous drugs.
The case was then elevated for review by the Supreme Court in G.R. No. 244287, with the substantive issue centering on the integrity of the chain of custody.

Whether the procedural requirements mandated under Section 21 of RA No. 9165 were complied with during the chain of custody.
Whether the absence of insulating witnesses during the inventory and photographing of the evidence undermines the integrity of the seized items.

Whether the failure to secure the presence of required representatives—namely a representative of the National Prosecution Service or media—during the inventory and photographic documentation created a broken chain of custody.
Whether the demonstrated irregularities in the chain of custody sufficiently erode the presumption of regularity in the law enforcers’ performance of their duties, thereby impacting the accused's constitutional right to be presumed innocent.

Whether the prosecution failed to explain or justify the deviation from the set procedure for handling dangerous drugs evidence.
Whether such deviations, amounting to a gap in the chain of custody, warrant the acquittal of the accused.