G.R. No. 238516 - People vs. Rodriguez y Martinez

The case involves the People of the Philippines charging Roger Rodriguez y Martinez, alias "Roger," with violations under R.A. No. 9165, the Comprehensive Dangerous Drugs Act of 2002.
Appellant was charged in two separate Informations for:

Illegal possession of dangerous drugs (Sections 11, Article II) involving two plastic sachets containing methamphetamine hydrochloride (0.20 gram and 0.220 gram).
Illegal sale of dangerous drugs (Section 5, Article II) involving the sale of one plastic sachet containing 0.07 gram of methamphetamine hydrochloride.

On October 3, 2010, an informant disclosed that Roger was allegedly engaged in the illegal sale of drugs.
The Special Operations Task Group of the Muntinlupa City Police Station, led by Chief Inspector Domingo Diaz, organized a buy-bust operation:

The operation was set in motion following a briefing with pre-operation reports, coordination forms, and preparation of the buy-bust money.

On the early morning of October 4, 2010, intelligence placed Roger at the Shell Gas Station in Barangay Alabang.
Upon arrival, the operatives strategically positioned themselves and identified the accused as he alighted from a tricycle.
The informant introduced PO2 Forastero in the guise of a buyer offering P500.00.
During the transaction:

Roger handed over one transparent plastic sachet (containing multiple smaller sachets with a crystalline substance) after receiving the marked money.
PO2 Forastero signaled the consummation of the transaction by touching his left ear and subsequently apprehended Roger.

The evidence included the sachet from the sale and additional sachets presumed to be in Roger’s possession.
The items were marked systematically as “RR”, “RR-1”, “RR-2”, and “RR-3” for identification.

After the buy-bust, the apprehending team transported Roger and the seized items to the police station.
The inventory of the confiscated drugs was prepared at the police station rather than at the scene:

The physical inventory was recorded and photographed.
Only a local government employee (LGE Ely Diang) signed as a witness, instead of the full complement of witnesses required by law (media, DOJ representative, or an elected public official).

Police officers handled the preparation of the request and turnover of the specimens to the Crime Laboratory.
A qualitative examination confirmed the presence of methamphetamine hydrochloride (shabu) in the items.

Convicted for illegal sale of dangerous drugs and sentenced to life imprisonment plus a fine.
Convicted for illegal possession with a sentence ranging from twelve years and one day to fourteen years and eight months, plus an additional fine.

Testimonies by PO2 Forastero, who identified Roger as the actor involved in the buy-bust operation.
The physical evidence presented, despite noted imperfections in the inventory process and chain of custody.

Roger appealed the RTC’s decision to the Court of Appeals (CA), which affirmed his conviction but modified the penalty regarding illegal sale by ruling he was not eligible for parole.
The CA underscored that despite procedural defects in the chain of custody, the integrity and evidentiary value of the seized drugs were sufficiently preserved.
The final appeal reached the Supreme Court, focusing on whether the CA properly adjudicated the evidence and procedural lapses.

Whether the Court of Appeals correctly found the appellant guilty beyond reasonable doubt for the crimes charged under R.A. No. 9165.

Specifically, did the evidence sufficiently establish the elements of both illegal sale and illegal possession of dangerous drugs?
Whether the prosecution’s failure to strictly comply with the chain of custody procedures (as mandated by Section 21 of R.A. No. 9165 and its IRR) undermined the integrity and evidentiary value of the seized drugs.

Whether the procedural lapses during the buy-bust operation and the subsequent inventory (including the absence of mandated witnesses such as media, DOJ representative, and an elected official) negatively affected the prosecution’s case and led to reasonable doubt on the accused’s criminal liability.