G.R. No. 192284 - Tionco y Ortega vs. People

Petitioner Alex Tionco y Ortega was charged with violating Section 11(3), Article II of Republic Act No. 9165 (The Comprehensive Dangerous Drugs Act of 2002).
The charge stemmed from an incident on or about July 24, 2002, in Manila, where the petitioner was alleged to have unlawfully possessed a plastic sachet containing 0.047 gram of a white crystalline substance identified as shabu (methamphetamine hydrochloride).

According to the prosecution’s version, at approximately 3:45 p.m. on July 24, 2002, police officers PO1 Joel G. Sta. Maria and PO1 Fernando Reyes, while on an anti-criminality patrol in Parola Compound, Tondo, observed the petitioner holding and examining a transparent plastic sachet.
The officers, after confirming the contents of the sachet, approached and subsequently arrested the petitioner, informing him of the alleged violation as well as his constitutional rights.

After the arrest, the confiscated plastic sachet was marked with the petitioner’s initials “ATO” by PO1 Sta. Maria and was turned over to PO1 Elymar Garcia.
The item, together with the request for forensic examination, was sent to the Western Police District (WPD) Crime Laboratory, where Forensic Chemist P/Insp. Judycel Macapagal conducted a qualitative analysis that confirmed the substance was indeed shabu.
The chain of custody was maintained through proper labeling and handling, thereby preserving the integrity and evidentiary value of the seized item.

The petitioner denied the charges, asserting that he was sitting in front of his uncle’s house when police officers unexpectedly approached and arrested him.
He claimed that during the arrest at Police Station 2, although he was frisked, nothing illegal was found on him.
Additionally, he alleged that PO1 Sta. Maria attempted to extort a sum of P6,000.00 from him in exchange for his release.

At the arraignment on December 9, 2002, the petitioner entered a plea of not guilty.
During pre-trial and trial, several testimonies, including those from PO1 Garcia and PO1 Sta. Maria, were either stipulated or dispensed with, reinforcing the narrative of the prosecution.
The Regional Trial Court (RTC) rendered an Amended Decision on August 29, 2008, convicting the petitioner beyond reasonable doubt and sentencing him to imprisonment (a term ranging from twelve years and one day to fifteen years) plus a fine of P300,000.00.
On appeal, the Court of Appeals (CA) affirmed the RTC decision on January 21, 2010, upholding both the elements of the offense and the chain of custody of the seized item.
The CA also issued a Resolution on May 13, 2010, denying the petitioner’s motion for reconsideration.

The prosecution’s evidence was presented through testimonial, documentary, and object evidence, particularly emphasizing the direct identification of the petitioner and the marked plastic sachet.
Despite minor discrepancies in the details of the petitioner’s positioning at the time of arrest, the consistent identification by PO1 Sta. Maria played a pivotal role in affirming his guilt.
The defense’s later-raised issues regarding the absence of a physical inventory and photographic documentation of the seized item were not contested during trial, thus affecting their admissibility on appeal.

Whether the Court of Appeals erred in giving full weight and credence to the prosecution’s evidence despite the apprehending team’s alleged failure to fully prove the integrity and identity of the confiscated shabu.
Whether the Court of Appeals committed a grave error in affirming the petitioner’s conviction in light of the alleged irregularities in the apprehending officers’ performance of their official duties.