G.R. No. 225744 - People vs. Vistro y Baysic

On or about June 4, 2009, in the afternoon at Acosta St., Poblacion, Urbiztondo, Pangasinan, the accused, Jonathan Vistro y Baysic, was alleged to have engaged in the sale, trade, and delivery of a heat-sealed plastic sachet containing 0.01 gram of methamphetamine hydrochloride (shabu).
The transaction was purportedly executed in conspiracy with others and targeted a poseur-buyer who was actually an agent of the Philippine Drug Enforcement Agency (PDEA).
The accused was charged with violating Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).

Following a tip-off by a police asset regarding the accused’s involvement in peddling shabu, PDEA officers in Pangasinan organized a buy-bust team.
Intelligence Officer Jaime Clave was designated as the poseur-buyer, receiving ₱500.00 as buy-bust money, and was assisted by IO Noreen Bautista as immediate backup, while other team members provided perimeter support.
At the scene, after the police asset introduced IO Clave to the accused, a transaction ensued wherein the accused handed over the drug sachet in exchange for the marked ₱500.00.
Following a prearranged signal by IO Clave indicating consummation of the deal, IO Bautista promptly arrested the accused.

Upon arrest, the buy-bust team withdrew from the area due to the discovery that local barangay officials (including the barangay captain, who was related to the accused) were present near the scene of the crime.
At the police station, IO Clave handled the seized shabu; it was marked in the presence of the accused.
IO Bautista prepared a Certificate of Inventory for the seized drug and arranged for its photographic documentation, with a barangay official from another barangay verifying the inventory.
The drug evidence was delivered to the police crime laboratory where tests confirmed that its contents were indeed shabu.

The accused contended that the PDEA officers, who were in civilian clothes, initially visited his residence in search of his parents, leading to confusion when they encountered family members and local officials.
He alleged that the presence of the barangay captain (a relative of his mother) and other officials contributed to a scenario where he and his family were involuntarily swept up in the operation.
The defense maintained that the sequence of events led to a misinterpretation of his involvement in the drug transaction.

In its November 14, 2013 Judgment, the RTC adjudged the accused guilty beyond reasonable doubt for violating Section 5, Article II of R.A. 9165.
The RTC credited the testimonies of the PDEA officers and maintained that the chain of custody of the seized shabu was unbroken and properly preserved.
Consequently, the accused was sentenced to life imprisonment, imposed a fine of ₱500,000.00, and Teresita Baysic was acquitted due to insufficiency of evidence.

On September 4, 2015, the CA affirmed the RTC’s decision, rejecting the accused’s contention regarding non-compliance with the procedural safeguards under Section 21, Article II of R.A. 9165.
The CA held that despite alleged lapses (such as the absence of certain required witnesses), the integrity of the chain of custody was largely upheld.

Whether the failure to secure the presence of all mandatory witnesses (specifically representatives from the media and the Department of Justice) during the physical inventory and photographic documentation of the seized shabu constituted a fatal flaw.
Whether such non-compliance undermined the integrity and evidentiary value of the chain of custody.

Whether the actions of the PDEA and police officers—despite evidentiary gaps—were sufficient to establish that the procedural requirements under Section 21, Article II of R.A. 9165 were met.
Whether the justification (or lack thereof) provided by the arresting officers for the absence of the required witnesses was acceptable under the law.

Whether the established chain of custody was enough to prove key elements of the offense, specifically the delivery of the drug and the authenticity of the corpus delicti.
Whether any lapse in procedures could lead to reasonable doubt as to the accused’s guilt.