G.R. No. 262732 - People vs. Mongcao Basaula Sabino a.k.a. "Mongkao Basaola Sabino" a.k.a. "Salik" and Saima Diambangan Mipandong

The case involves accused-appellants Mongcao Basaula Sabino a.k.a. “Mongkao Basaola Sabino” a.k.a. “Salik” and Saima Diambangan Mipandong who were charged with the illegal sale of dangerous drugs under Section 5 of Republic Act No. 9165.
The accusatory portion of the Information detailed that on or about March 31, 2018 in Quezon City, the accused, acting in concert, sold four knot-tied transparent plastic bags containing specific weights of methamphetamine hydrochloride (shabu) totaling approximately 539.9978 grams.

A buy-bust operation was initiated after a tip-off regarding an alias “Salik” linked to the illegal drug trade in Lanao del Sur, who was believed to have relocated to Quezon City.
A team from the Philippine Drug Enforcement Agency (PDEA), including agents such as Alexis Anonas, Christopher Embang, Geona Recibido, and Jonar Cuayzon, coordinated the operation.
A buy-bust team was formed with specific roles: an informant facilitated contact with the alleged drug trader, and designated PDEA agents assumed the roles of poseur buyer and immediate back-up.
The deal was arranged between the informant and alias “Salik” for the sale of 500 grams of shabu at a price of PHP 1,250,000.00, to be executed at the parking lot of Robinsons Mall in Novaliches, Quezon City.

Agent Cuayzon instructed the informant to contact “Salik” and arrange the meet-up.
Agents Anonas and Embang were in an unmarked buy-bust vehicle, with additional agents on perimeter backup.

When a Toyota Revo arrived, Sabino and Mipandong emerged and were invited into the vehicle. During the transaction:

Sabino handed over a gray pouch to Agent Anonas, who then revealed four knotted plastic bags containing white crystalline substance.
Payment was exchanged with a paper bag that contained marked PHP 100.00 bills on top of fake money.

Beyond the drug pouches and money, the PDEA agents also seized a mobile phone, identification cards from Sabino, and the Toyota Revo used by the accused.
The evidence was immediately marked by Agent Anonas in the presence of both accused, after which the team transported them to the PDEA headquarters for further inventory.

Upon arrival at the PDEA office, an inventory of the seized items was conducted in the presence of external witnesses (Barangay Kagawad Marites Palma and radio reporter Jimmy Mendoza).
The evidence, including the white crystalline substance, was turned over to Chemist Anna Loe Montilla at the PDEA Laboratory Service, where it was positively identified as methamphetamine hydrochloride.
Additionally, urine samples from both accused were tested, returning negative for methamphetamine and other controlled substances.

Both Sabino and Mipandong pleaded “not guilty” at arraignment and later presented an alibi:

Sabino claimed he was a construction worker who borrowed his aunt’s Toyota Revo to fetch his brother-in-law coming from the pier, and while en route, he encountered Mipandong, whom he invited to ride along.
During the wait at a mall parking lot, Sabino recounted an incident with a friend, which culminated in his mistaken identification as “Salik” during a struggle with unidentified men.
Mipandong’s account was linked to being with Sabino but without independent corroboration.

The Regional Trial Court (RTC) found both accused guilty of illegal sale of dangerous drugs, noting that the prosecution had established all elements of the crime (identification of seller and buyer, the substance, money, and delivery).
The Court of Appeals (CA) affirmed the RTC’s decision, addressing the procedural lapses under Section 21 of RA 9165 by applying its saving clause given the justifiable grounds present during the operation.
A subsequent appeal was made but ultimately denied, with supplemental briefs emphasizing the sufficiency of the chain of custody and the integrity of the seized evidence.

Whether the prosecution was able to prove beyond reasonable doubt that Sabino and Mipandong were guilty of the illegal sale of dangerous drugs under Section 5 of Republic Act No. 9165.
Whether the deviations from the prescribed procedural requirements under Section 21 of RA 9165—specifically the noncompliance in conducting the physical inventory at the buy-bust location—compromised the integrity and evidentiary value of the seized drugs.
Whether the justifiable grounds for departure from strict compliance with Section 21 were sufficiently established to invoke the saving clause.