People vs. Jeryl Bautista

G.R. No. 255749
Buy-bust: Delay in marking shabu led to acquittal for sale; possession conviction upheld due to valid search.
corpus delicti dangerous drugs illegal possession

Case Digest (G.R. No. 255749)

Facts:

People of the Philippines v. Jeryl Bautista y Martinez, G.R. No. 255749, October 15, 2025, the Supreme Court First Division, Rosario, J., writing for the Court.

The accused-appellant, Jeryl Bautista y Martinez, was charged in two separate Informations: Criminal Case No. SCC-9606 for illegal possession of dangerous drugs (three heat-sealed sachets of methamphetamine hydrochloride totaling 2.07 grams) and Criminal Case No. SCC-9607 for illegal sale of dangerous drugs (one heat-sealed sachet sold to a poseur-buyer for PHP 500). Bautista pleaded not guilty to both charges. The San Carlos City PNP received a tip on August 27, 2017, validated it, and conducted a buy-bust operation with PO2 Mark Argel De Guzman as the poseur-buyer; PSINSP Darwin Zafra led the team and PO1 Rommel Tuazon was the arresting officer.

According to the prosecution, Bautista delivered one sachet to the poseur-buyer and was arrested after the prearranged signal; during a search at the place of arrest and in the presence of a DOJ representative and two barangay kagawads, officers recovered three additional sachets concealed in a cellphone charger plus marked money and other items. The seized items were marked, inventoried, photographed, tested positive for methamphetamine hydrochloride, and submitted in evidence. Bautista denied the charges, alleging abduction, planting of evidence, and inconsistencies in police accounts.

The Regional Trial Court (Branch 57, San Carlos City) convicted Bautista of both offenses in a January 11, 2019 decision and imposed penalties. The Court of Appeals (Fourteenth Division) affirmed in an October 6, 2020 decision. Bautista appealed to the Supreme Court; the People adopted their CA brief and Bautist...(Pro-only)

Issues:

  • Whether the prosecution established the movement and custody of the corpus delicti and complied with the requirements of Section 21, RA 9165 (and related jurisprudence) so as to sustain conviction for illegal sale (evidentiary admissibility/procedural issue)?
  • Whether the warrantless search that produced the three sachets found on Bautista was lawful as a search incident to a lawful arrest (and thus admissible) or required plain-view justification (substantive search-and-seizure issue)?
  • What is the proper penalty for illegal possession of dangerous drug...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)
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