G.R. No. 227394 - People vs. Sood y Amatondin

The Information charged accused-appellant Norjana Sood y Amatondin with violating Section 5, Article II of RA 9165 by unlawfully selling, trading, and delivering 5.85 grams of methylamphetamine hydrochloride (shabu) on January 28, 2009.
According to the prosecution, the sale occurred after a covert buy-bust operation involving:

A confidential informant (“Florence”) who initiated contact via mobile phone, arranging a meeting with the accused.
A team of police operatives from the Station Anti-Illegal Drugs-Special Operation Task Group, Kamuning Police Station, working to intercept the alleged drug transaction.
The subsequent identification and arrest of the accused when she handed over two transparent plastic sachets sealed with markings indicating the seizure date.

Testimonies of police officers (SPO1 Regato and PO1 Hega) regarding the arrest and subsequent handling of the seized items.
An inventory of seized items purportedly made either at a barangay hall or a police station, although the exact location remains inconsistent.
Laboratory test results confirming the presence of shabu in the submitted specimens.

Accused-appellant denied engaging in any drug sale, asserting that on the day of the apprehension she was merely operating as a sidewalk vendor along the Luzon Overpass.
She claimed that the individuals who apprehended her were not bona fide law enforcers but persons impersonating officials (purportedly from the Metro Manila Development Authority).
Further, she alleged extortion, stating that the apprehending officers demanded a sum of thirty-five thousand pesos for her release—a claim she did not pursue legally.

The Regional Trial Court (RTC) of Quezon City, in its Decision dated January 24, 2013, convicted the accused-appellant for the sale of dangerous drugs and imposed life imprisonment along with a fine of PHP500,000.
The RTC acknowledged a lapse in complying with Section 21 of RA 9165 (failure to conduct the inventory at the exact place of seizure), but found that the police officers’ explanations justified the deviation.
The Court of Appeals (CA), in its Decision dated September 18, 2015, affirmed the RTC’s conviction, reiterating that despite the inconsistencies in the inventory procedure, there was “substantial compliance” because the integrity of the evidence was preserved and the chain of custody was allegedly maintained.

The prosecution’s version rested on the premise that with proper marking, inventory, and laboratory confirmation, the chain of custody of the shabu was unbroken—even though:

There were conflicting testimonies on the location and manner of the inventory and photographing of the seized drugs.
Not all required witnesses (a representative from the Department of Justice, media, and an elected public official) were present at the time of inventory.

The defense emphasized these discrepancies to argue that no bona fide buy-bust operation occurred and to question the integrity of the evidence.

Whether the prosecution was able to prove beyond reasonable doubt that accused-appellant committed the illegal sale of shabu as charged under Section 5, Article II of RA 9165.
Whether the non-compliance with the mandatory procedural requirements under Section 21 of RA 9165—specifically, the immediate physical inventory and photographing of seized items in the presence of three required witnesses—affected the integrity of the chain of custody.
Whether the conflicting testimonies of the buy-bust team regarding the place and manner of the inventory undermine the credibility of the evidence presented against the accused.