G.R. No. 247973 - People vs. Samson y Cruz

The case originated from an Information filed before the RTC charging accused-appellant Nadjera Tamundi y Pamlian with illegal sale of dangerous drugs under Section 5, Article II of RA 9165.
The Information alleged that on or about January 10, 2015, in Quezon City, Tamundi, not authorized to sell dangerous drugs, sold 295.53 grams of Methamphetamine Hydrochloride (shabu).
On January 9, 2015, a buy-bust operation was organized at Camp Crame under the supervision of PNP officials. P/Supt. Dwight Monato led the team with PO3 Junel Dela Cruz designated as the poseur-buyer and SPO2 Michael Calimlim as the backup/arresting officer.
Based on a tip from a confidential informant (CI), the designated poseur-buyer sealed a deal with an alleged drug seller referred to as “alias Ed” for the purchase of 300 grams of shabu for P300,000.00.
At approximately 3:45 a.m. on January 10, 2015, PO3 Dela Cruz and the CI arrived at the agreed location near Burger King along Timog Avenue, Quezon City, where they signaled their arrival.

Tamundi approached the buy-bust team, entered their vehicle, and inquired about the money. PO3 Dela Cruz confirmed the availability of the money—comprising one P1,000.00 genuine bill marked on a stack of boodle money.
Tamundi handed over a black paper bag (marked with a Guess logo) containing the suspect shabu, in exchange for the buy-bust money.
Upon receipt of the contraband, PO3 Dela Cruz activated the parking lights of the van, prompting SPO2 Calimlim and the rest of the team to intervene in the transaction.
Tamundi was arrested by SPO2 Calimlim, and the money was recovered from her person.
The incriminating items—the marked money and the black paper bag containing shabu—were later subjected to an inventory process, which was witnessed by media representative Rod Vega of DZBB and Barangay Kagawad Pedro B. Battung, Jr. from West Triangle.

After the buy-bust operation, the confiscated items were transferred to the police station. PO3 Dela Cruz maintained possession of the contraband until its turnover.
The black Guess bag containing the contraband was transferred to PO3 Ernesto PeAa, Jr., who coordinated the preparation of affidavits, requests for laboratory and drug examinations.
The evidence was submitted to the PNP Crime Laboratory where Forensic Chemist PCT Alejandro de Guzman (PCI De Guzman) conducted tests that confirmed the presence of methamphetamine hydrochloride.
Subsequent custody was maintained by PO2 Ryan Castillo, ensuring an unbroken chain-of-custody from seizure to court presentation.
Despite an anomaly in the inventory receipt—where media representative Vega did not sign due to his company policy—the presence of his name with “RTS” (Refused to Sign) was noted, and the integrity of the chain was maintained.

Tamundi denied the allegations, claiming she was at a Cash and Carry outlet in Makati City with her sister on the evening of January 9, 2015.
According to her account, police officers forcibly involved her in a sequence of events that led to her being taken to Camp Crame and later to Burger King.
She asserted that following the encounter at Burger King, she was transferred from one vehicle to another while her sister was left behind.
Tamundi further claimed that during this period, police officers demanded P50,000.00 in exchange for her release—an allegation she maintained when she failed to produce the sum.
Notably, her defense witnesses (her sister, her brother-in-law, and his wife) did not appear to testify in court.

The RTC, in its Decision dated September 17, 2018, convicted Tamundi beyond reasonable doubt for illegal sale of dangerous drugs and sentenced her to life imprisonment with a P500,000.00 fine.
The RTC ruled that all elements of the crime were present, giving greater weight to the positive identification by the police officers involved.
On appeal, the Court of Appeals, in its Decision dated June 29, 2020, affirmed the conviction by reiterating that the sale took place as established through the identification of the buyer and seller, presentation of the corpus delicti, and an unbroken chain-of-custody.
The appellate court justified the slight deviation in inventory procedure—specifically, the absence of the media representative’s signature—by noting that his presence was adequately established through alternative means (testimony and photographs).

Whether the evidence presented, including the identification of the buyer and seller, the exchange of money and contraband, and the unbroken chain-of-custody, is sufficient to support a conviction for illegal sale of dangerous drugs under RA 9165.

Was the value and integrity of the evidence (marked money and confiscated shabu) maintained despite the absence of a signature from one of the required witnessing parties?
Can Tamundi’s denial and alternative account of the events be given credence when no corroborative witnesses testified in support of her version?

Whether the deviation from the procedural requirement under Section 21 of RA 9165—specifically, the media representative’s refusal to sign the inventory receipt—compromised the evidentiary value and admissibility of the seized contraband.