Facts:

The case revolves around Ruper Posing y Alayon, who was charged with the illegal sale and possession of drugs under Republic Act No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002. The prosecution's case began on August 13, 2003, when a police asset reported to the Station Anti-Illegal Drugs (SAID) about Posing's known drug-pushing activities in Makabayan St., Kamuning, Quezon City. Consequently, Chief P/Inspector Arturo Caballes organized a buy-bust operation and provided SPO1 Purisimo Angeles with PHP 100.00 marked money. Angeles, accompanied by officers PO1 Jesus Cortez and PO1 Ralph Nicart and the informant, proceeded to the area where they approached Posing. After being introduced as a potential buyer, Angeles requested to buy PHP 100.00 worth of shabu, to which Posing complied, handing over a sachet of the drug in exchange for the marked bill. After Posing completed the transaction, police officers apprehended him, recovering the buy-bust money a

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Facts:

Incident Initiation

• On August 13, 2003, an asset based at Makabayan St., Brgy. Obrero, informed the Station Anti Illegal Drugs (SAID) duty officer about the illegal activities of Ruper Posing y Alayon, a known drug pusher in their barangay.
• Acting on this tip, Chief P/Inspector Arturo Caballes immediately organized a team for a buy-bust operation, signaling the start of the coordinated law enforcement effort.

Execution of the Buy-Bust Operation

• SPO1 Purisimo Angeles, PO1 Jesus Cortez, PO1 Ralph Nicart, and an informant were dispatched to Makabayan St., Brgy. Obrero, Kamuning, Quezon City.
• Upon arrival at the squatteras area near a basketball court, SPO1 Angeles and the informant approached the suspect.
• The informant introduced Ruper Posing as a seller of shabu, prompting SPO1 Angeles to engage in a transaction for Php100 worth of shabu intended for personal use.
• During the transaction, Posing produced one transparent plastic sachet which was handed over to SPO1 Angeles in exchange for the marked buy-bust money.

Arrest and Seizure of Evidence

• After the exchange, SPO1 Angeles signaled the completion of the transaction by removing his cap, which was a prearranged signal to his colleagues.
• PO1 Cortez and PO1 Nicart rushed to the scene, identified themselves as police officers, and proceeded to arrest the suspect.
• During the arrest, another transparent plastic sachet was recovered from the suspect’s left palm along with the buy-bust money.
• SPO1 Angeles promptly marked both drug specimens before turning them over to the desk officer, ensuring initial documentation of the seized evidence.

Inventory, Laboratory Examination, and Stipulations

• The marked plastic sachets were transferred to PO2 John Sales, who prepared the necessary request for laboratory examination.
• The specimens were delivered to the Philippine National Police (PNP) Crime Laboratory by PO1 Nicart for both quantitative and qualitative examination.
• Engr. Leonard Jabonillo, the forensic chemist, conducted the examination and confirmed that each sachet contained 0.03 gram of shabu (methylamphetamine hydrochloride), thereby substantiating the evidentiary basis for the charges.
• The testimonies of both Engr. Jabonillo and PO2 Sales were stipulated by the parties, ensuring that critical procedural steps and evidence handling were jointly acknowledged.

Charging and Trial Proceedings

• Based on the operation:
• Criminal Case No. Q-03-120266 was filed for illegal sale of dangerous drugs under Section 5, Article II of R.A. No. 9165.
• Criminal Case No. Q-03-120267 was filed for illegal possession of dangerous drugs under Section 11, Article II of R.A. No. 9165.
• The accused, Ruper Posing y Alayon, entered a plea of not guilty upon arraignment on December 2, 2003.
• On December 2, 2008, the trial court found him guilty beyond reasonable doubt for both charges, imposing:
• Life imprisonment and a fine of Php500,000.00 for the sale charge.
• An indeterminate penalty of imprisonment (twelve years and one day to fourteen years) and a fine of Php300,000.00 for the possession charge.

Appellate Arguments and Resolution of Chain of Custody Issues

• On appeal, the accused contended that various lapses in handling and documenting the seized drugs (such as failure to properly mark the evidence and prepare an inventory report) broke the chain of custody.
• The defense further argued that the lack of prior surveillance and coordination with the Philippine Drug Enforcement Agency (PDEA) undermined the integrity of the investigation.
• Conversely, the People, represented by the Office of the Solicitor General, maintained that the police’s actions were within the bounds of regular procedure and that non-compliance with strict procedural technicalities did not nullify the evidence.
• The Court of Appeals affirmed the trial court’s ruling, finding the chain of custody requirements met and the integrity of the evidence preserved throughout the investigative process.

Issue:

Chain of Custody and Evidentiary Integrity

• Whether the procedural lapses alleged by the accused-appellant (e.g., failure to recall specific officers involved, improper immediate marking at the scene, and absence of an inventory report or photographic documentation) constituted a break in the chain of custody of the seized drugs.
• Whether such alleged lapses were sufficient to undermine the authenticity and reliability of the drug evidence presented in court.

Guilt Beyond Reasonable Doubt

• Whether the prosecution effectively established the essential elements of illegal sale of dangerous drugs, including the identification of the buyer and seller, the object and consideration, and the delivery of the drug.
• Whether the prosecution successfully proved that the accused had unlawful possession of dangerous drugs, thus satisfying the elements required under Section 11 of R.A. No. 9165.

Admissibility of Evidence Despite Procedural Non-Compliance

• Whether the demonstrated lapses in procedural protocol related to the handling and custody of the evidence warranted the suppression of the seized drugs.
• Whether precedence and established jurisprudence support the position that less-than-strict compliance with the chain of custody requirements does not automatically render evidence inadmissible if the integrity is maintained.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)