G.R. No. 227187 - People vs. Sevilla

Appellant Eric L. Sevilla was charged with violating Sections 5 and 11, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
The charges pertained to the illegal sale and illegal possession of dangerous drugs—in this instance, marijuana.
The case arose from two separate Informations:

In Panabo City, Davao, information was received by Agent Caludito CaAada from a confidential informant regarding a suspect (alias Eric) engaged in selling marijuana at Purok 6, Barangay Quezon.
A buy-bust operation was organized:

IO1 Julius A. Magdadaro acted as the poseur-buyer.
SO2 Bryan P. Ponferrada served as the back-up and later participated in the arrest.

The arrangement that the lighting of a cigarette by IO1 Magdadaro would signal the consummation of the transaction.
Preparation of a Php100.00 marked money bill (with initials “JAM”) to be used in the transaction.

At around 5:15 p.m., the buy-bust team, along with a confidential informant, identified and apprehended the suspect at a nipa hut.
Details of the transaction and arrest:

Appellant exchanged two packets of dried marijuana for the marked money.
After lighting a cigarette to signal consummation, SO2 Ponferrada intervened, handcuffed the appellant, and conducted a frisk.
From the appellant’s right pocket and bag were recovered: the Php100.00 bill, two packets involved in the buy-bust, and an additional ten packets of suspected marijuana.

Both sets of evidence (the two packets and the ten packets) were marked by the respective officers (IO1 Magdadaro and SO2 Ponferrada) in the presence of the appellant and other witnesses (media personnel, a DOJ representative, an elected official, and appellant’s representative).
The items were transported to the Panabo City Police Station for inventory and proper photographic documentation.
Seized drugs were forwarded to the Provincial Crime Laboratory in Tagum City where SPO2 Romeo Obrero received, weighed, and subsequently turned them over to the evidence custodian and then to the forensic chemist, P/Supt. Julieta G. Razonable, for chemical examination.
Laboratory results confirmed the presence of marijuana with each packet individually marked for identification.

On December 1, 2014, the RTC rendered a judgment finding the appellant guilty beyond reasonable doubt for both the offense of illegal sale and illegal possession of dangerous drugs.
The RTC rejected the defenses of denial and alibi as inherently weak.
Penalties imposed:

For sale: Life imprisonment (originally including the option of death, adjusted in light of RA 9346) and a fine of Php500,000.00.

ii. For possession: Imprisonment of twelve (12) years and one (1) day to thirteen (13) years and a fine of Php300,000.00.

On July 29, 2016, the CA affirmed the RTC’s decision.
The CA emphasized that the prosecution established a clear and unbroken chain of custody for the seized drugs, thereby upholding the integrity of the evidence.

The appeal filed by Eric L. Sevilla was resolved, with the higher court dismissing the appeal as unmeritorious.
The rulings of both the RTC and the CA were consolidated in the final decision.

Whether the apprehending officers complied with the requirements of Section 21 of RA 9165 regarding the physical inventory, photographic documentation, and proper chain of custody of the seized drugs.
Whether any deviations (e.g., delay or differences in the sealing procedures) compromised the evidentiary integrity of the confiscated marijuana.

Whether the prosecution sufficiently established that the marijuana presented in court was the same as that seized at the crime scene despite alleged procedural irregularities.
Whether the evidence maintained the required degree of certitude (moral certainty) to sustain a conviction beyond reasonable doubt.

Whether the elements for illegal sale of dangerous drugs (i.e., identification of the buyer and seller, object of the sale, consideration, and delivery) were satisfactorily proven.
Whether the defendant’s possession of the drugs was established with a clear demonstration of free and conscious control over the items.