G.R. No. 194945 - People vs. Watamama y Esil

An informant reported to SPO2 Dante Nagera at the Quezon City Anti-Drug Action Center that a person known as "aAlexa" was selling drugs in Barangay Payatas, Quezon City.
SPO2 Nagera relayed the information to his superior, P/Supt. Gerardo Ratuita, who then orchestrated a buy-bust operation.
A team was formed consisting of SPO2 Dante Nagera, PO3 Leonardo Ramos, PO1 Teresita Reyes, PO1 Alexander Jimenez, and PO1 Peggy Lynne Vargas.
PO1 Vargas was designated as the poseur buyer and was provided with two P100 bills which she marked with her initials (PVa) for identification.

At 12:00 noon on September 25, 2005, the team arrived at Area A in Barangay Payatas and proceeded to a house at No. 14 Rosal Street.
The informant accompanied PO1 Vargas to the location and introduced her to the accused, Alex Watamama y Esil, identifying him as a shabu user.
PO1 Vargas requested to purchase shabu worth P200 and, upon being given the two marked P100 bills, the accused exchanged the money for a plastic sachet containing 0.18 grams of shabu.
After the transaction signal was given by PO1 Vargas, the rest of the buy-bust team emerged, and the accused was immediately arrested.
During the arrest, the marked bills were recovered when SPO2 Nagera instructed the accused to empty his pockets, and the accused was subsequently taken to the police station.

At the police station, PO1 Vargas marked the confiscated shabu and handed it over to station investigator Alex A. Jimenez, who then prepared an inventory receipt signed by P/Supt. Ratuita.
The plastic sachet was later brought by PO2 Ortiz to the PNP Crime Laboratory for qualitative examination.
Forensic chemist Leonard Jabonillo conducted the examination, confirming that the contents of the heat-sealed transparent plastic sachet (marked PV-09-25-05) weighed 0.18 grams and tested positive for methylamphetamine hydrochloride (shabu).

The accused, Alex Watamama y Esil, claimed that three men in civilian attire, armed with handguns, suddenly invaded his house and arrested him without presenting an arrest warrant.
He maintained that no drugs or incriminating items were found on him during subsequent police frisking at the police station.
The accused also alleged that PO1 Jimenez coerced him by threatening his release in exchange for the identity of a big-time shabu supplier, a claim which he denied by asserting he neither sold shabu nor had knowledge of such a supplier.

The Regional Trial Court (RTC), Branch 103 of Quezon City, convicted the accused of the illegal sale of 0.18 grams of shabu and sentenced him to life imprisonment along with a fine of P500,000.
On appeal, the Court of Appeals (CA) affirmed the RTC’s decision.
The CA held that the chain of custody of the seized shabu was established, noting that the marking and inventory procedures—even if not perfectly executed at the scene—had preserved the integrity and evidentiary value of the seized items.

The accused challenged the compliance of the arresting officers with Section 21(1) of R.A. No. 9165, arguing that the necessary procedures for marking, inventory, and presence of appropriate representatives were not strictly adhered to during the seizure.
Despite the CA’s acceptance that deviations (such as not marking at the scene because of the crowd and loss of the digital camera) did not fatally impair the evidence, the issue of an incomplete chain of custody was raised.
The CA emphasized established protocols under the Implementing Rules and Regulations of R.A. No. 9165, but also noted that minor imperfections might be tolerated if the integrity of the evidence is maintained.

The accused filed a notice of appeal before the Supreme Court, questioning the noncompliance in the custody and control of the seized drugs, and asserting that the prosecution failed to adequately demonstrate the chain of custody for the evidence.
The Court reviewed the necessary links in the chain of custody as required by precedent (such as People v. Kamad), which include:

The prosecution’s reliance solely on PO1 Vargas' testimony, without corroborative testimony from the investigator and PO2 Ortiz regarding the handling and storage of the evidence, was deemed insufficient to satisfactorily establish the chain of custody.

Whether the prosecution was able to establish an unbroken and credible chain of custody for the seized shabu, thereby proving that the evidence presented in court was indeed the same substance seized from the accused.
Whether the alleged noncompliance with the procedural requirements under Section 21(1) of R.A. No. 9165—specifically the failure to mark and inventory the evidence at the scene or in the presence of representatives—undermined the integrity of the evidence.
Whether the over-reliance on the testimony of a single officer (PO1 Vargas) without corroboration from other key witnesses in the chain of custody renders the evidence inadmissible due to compromised evidentiary integrity.