G.R. No. 244545 - Reyes, Jr. y De Los Reyes vs. People

The Laoag City Police Station planned a buy-bust operation after receiving information from a “police asset” that Franklin Reyes, also known as “idol”, was peddling illegal drugs along Magat Salamat Street.
During the briefing, PO1 Irving Lorenzo was designated as the poseur-buyer, while PO1 Jay Joemar Corpuz and other police officers acted as back-up.
The police asset sent a text message to Reyes that someone was interested in buying shabu (methamphetamine hydrochloride) worth P1,000.00.
Upon arriving at the target area, Reyes invited the officers inside one unit of a four-door apartment where he met with PO1 Lorenzo.
During the clandestine transaction, Reyes handed a small plastic sachet containing a white crystalline substance in exchange for the marked P1,000.00 bill.
Following the agreed pre-arranged signal by PO1 Lorenzo, he identified himself as a police officer and arrested Reyes.

After the arrest, police officers frisked Reyes and recovered additional items: a small brown paper envelope, the P1,000.00 buy-bust money, and three other sachets purportedly containing illegal drugs.
The buy-bust team transported Reyes to the police station and called upon members of the media as well as barangay officials; however, only Barangay Kagawad Helen Bulaun arrived.
The seized items were marked and photographed in the presence of Reyes and Kagawad Bulaun.
PO1 Lorenzo and PO1 Corpuz personally delivered the items to the Philippine National Police (PNP) Crime Laboratory, where the specimens tested positive for shabu.

Criminal Case No. 17067-14 for Illegal Sale of Dangerous Drugs, alleging that he sold a sachet containing methamphetamine hydrochloride.
Criminal Case No. 17068-14 for Illegal Possession of Dangerous Drugs, alleging that he had possession of three additional sachets.

Reyes denied the accusations, asserting that he was alone in his apartment working on an extension cord when police officers, without proper procedure, arrested him.
Reyes claimed he was not frisked, and testified that items were not recovered from him; he further noted that the police officers used undue force in arresting and detaining him.
Barangay Kagawad Bulaun testified that she was not present during the actual operation and marking of the seized items; her role was confined to certifying Reyes’ residency and acknowledging the presence of the items.

In Criminal Case No. 17067-14, Reyes was found guilty of illegal sale of dangerous drugs and sentenced to life imprisonment and a fine of P500,000.00.
In Criminal Case No. 17068-14, Reyes was found guilty of illegal possession of dangerous drugs with an indeterminate penalty (13 to 15 years) and a fine of P300,000.00.

Reyes appealed the RTC decision to the Court of Appeals (CA) in CA-G.R. CR-HC No. 09273, where the CA affirmed the RTC’s findings with a modification increasing the fine in the possession case to P350,000.00.
Reyes further moved for reconsideration which was denied, prompting elevation of the case to the Supreme Court.

Reyes contended that the chain of custody of the seized drugs was broken due to the absence of key insulating witnesses, specifically representatives from the National Prosecution Service or media.
Testimonies during the trial, particularly those of PO1 Lorenzo and Barangay Kagawad Bulaun, revealed irregularities:

PO1 Lorenzo’s testimony indicated that only a barangay official (Kagawad Bulaun) was present during the marking and inventory, while media and other officials were absent.
Kagawad Bulaun admitted she did not personally witness the marking or inventory process, reducing her role to mere certification of the items.

The prosecution failed to provide justifiable reasons for the noncompliance of the procedural requirements under Section 21 of RA 9165, which mandates the presence of insulating witnesses.

Whether the prosecution sufficiently proved beyond reasonable doubt that the chain of custody of the seized drugs was unbroken and valid.

Did the absence of a representative of the National Prosecution Service or the media as an insulating witness compromise the integrity of the evidence?
Can testimonies of the police officers and a barangay official, who did not fulfill their required roles, support the inference of an unbroken chain of custody?

Whether the failure to comply with the procedural requirements under Section 21 of RA 9165 undermines the demonstration of the corpus delicti in cases of Illegal Sale and Possession of Dangerous Drugs.

Does the lack of proper documentation and presence of all required witnesses invalidate the evidence presented against Reyes?
Are the deviations from the mandated procedure sufficient to destroy the presumption of regularity in handling the seized items?