G.R. No. L-18034 - Buenaventura vs. Ramos

The accused, Baida Salak y Bangkulas, was charged with the illegal sale of a regulated drug—methamphetamine hydrochloride (shabu)—in violation of Section 15, Article III of Republic Act No. 6425 (Dangerous Drugs Act of 1972, as amended by RA No. 7659).
The charge stemmed from a transaction that allegedly occurred on May 23, 2001, in Quezon City, where the accused was purportedly selling 305.4604 grams of shabu.

The National Bureau of Investigation (NBI) received intelligence that "Baida" was engaged in selling shabu at Litex Market, prompting the formation of an NBI Special Task Force (STF) composed of various operatives.
A surveillance operation was conducted which involved:

Deployment of NBI Special Investigator Edgardo Kawada, Sr. as a poseur-buyer.
Involvement of other agents, including Supervising Agent Dominador Villanueva III and additional investigators, who coordinated the stakeout and subsequent operations.

The operation included a series of location changes based on instructions from the accused involving venues such as Greenwich Pizza Parlor, McDonald’s restaurant, and finally the designated meeting place at Litex Market.

During the operation, the accused, accompanied by two men identified as her husband and an associate (later introduced respectively as Karim Salak and Boy Life), negotiated the sale of shabu.
The buy-bust operation culminated with:

A negotiated price of P180,000 for approximately 300 grams, later accounting for a total weight of 305.4604 grams.
The physical exchange of money for three small heat-sealed plastic sachets containing the shabu.

Immediately after the transaction took place, Special Investigator Kawada revealed his status as an NBI operative and arrested the accused.
The confiscated sachets, each marked (REM-1, REM-2, and REM-3), were submitted for forensic analysis. The NBI Forensic Chemist certified that the substances tested positive for methamphetamine hydrochloride with an average purity of 87.99%.

Testimonies of the NBI operatives detailing the sequence of events during the stakeout and transaction.
Forensic evidence, including the Certification by NBI Forensic Chemist Juliet Gelacio-Mahilum attesting to the substance’s composition and weight.

The marking and documentation by the NBI team.
The proper transmittal of evidence to the NBI Forensic Chemistry Division shortly after the operation.

She claimed that on the morning of May 23, 2001, she was at her market stall with her husband when an acquaintance and her companions (including a person named Aminola Kawada) visited with the intent to purchase items unrelated to drugs.
According to the defense, the subsequent events involved a series of misunderstandings, wrongful apprehensions, and even alleged threats.

The procedural requirements for documenting and photographing the seized drugs, as mandated by Dangerous Drugs Board regulations, were not complied with.
The absence of the buy-bust money as evidence raised doubts about the integrity of the prosecution’s case.

The Regional Trial Court (RTC), Branch 103 of Quezon City, initially ordered a provisional dismissal on September 25, 2001 due to the repeated failure of prosecution witnesses to attend hearings, but this order was orally recalled when key witnesses appeared.
The RTC eventually rendered a decision on February 18, 2002, convicting the accused beyond reasonable doubt and sentencing her to reclusion perpetua along with a substantial fine.
The Court of Appeals (CA) affirmed the RTC’s decision in its Decision dated February 21, 2007, which was later challenged on appeal before the Supreme Court.

Her right to due process was violated by the manner in which the case was revived following the provisional dismissal.
The evidence presented by the prosecution was insufficient and marred by inconsistencies, including alleged lapses in fulfilling Dangerous Drugs Board procedures and mishandling of buy-bust money.

She asserted that these irregularities introduced reasonable doubt as to the integrity and admissibility of the seized drugs evidence.

Whether the non-compliance with Dangerous Drugs Board regulations concerning the physical inventory and photographic documentation of confiscated drugs affected the integrity or admissibility of the evidence.
Whether the revival of the case, following an oral provisional dismissal that had not been reduced to writing, violated the accused’s right to due process.
Whether the evidence presented by the prosecution, including the chain-of-custody and forensic analysis, was sufficient to convict the accused beyond reasonable doubt of the illegal sale of a regulated drug.
Whether the alleged failure to present the buy-bust money during trial compromised the prosecution’s case or created an evidentiary gap that warranted acquittal.
Whether the sequence of events and the conduct of the NBI operatives, notwithstanding minor procedural lapses, were adequate to establish the essential elements of the crime charged.