G.R. No. 190749 - Zafra y Dechosa vs. People

On 12 June 2003 at around 4:30 PM in Balagtas, Bulacan, SPO4 Apolinario Mendoza conducted surveillance for drug trafficking in front of a sari-sari store at the corner of Miraflor Subdivision and P. Castro Street.
From a distance, Mendoza claimed to have observed petitioners Valentin Zafra y Dechosa and Eroll Marcelino y Reyes each holding a sachet of shabu, while a third person, Marlon Daluz, held an aluminum foil and lighter. He approached, confiscated two sachets of shabu from Zafra and Marcelino, and paraphernalia from Daluz, brought all three to the Balagtas Police Station, and marked the sachets “VSD” and “EMR.”

On 13 June 2003, Mendoza sent the accused and seized items to the crime laboratory. Tests confirmed the presence of methylamphetamine hydrochloride in the two sachets (0.31 g and 0.30 g).
The RTC of Malolos, Bulacan, convicted Zafra and Marcelino of illegally possessing dangerous drugs under Section 11, Article II of RA 9165, sentencing each to 12 years and one day to 13 years imprisonment and a ₱300,000 fine. Daluz pleaded guilty to possessing drug paraphernalia, served eight months, and was released.

The Court of Appeals, in CA-G.R. CR No. 31713, affirmed the RTC decision in full on 30 October 2009.
Petitioners elevated the case to the Supreme Court, challenging (a) the legality of their arrest, (b) admissibility of the seized drugs, (c) compliance with Section 21 of RA 9165, and (d) sufficiency of evidence to prove guilt beyond reasonable doubt.

Whether the arrest and warrantless seizure of the sachets of shabu were lawful.
Whether the integrity and identity of the seized drugs were preserved, satisfying the chain-of-custody requirement under Section 21, Article II of RA 9165 and its IRR.
Whether the lone testimony of SPO4 Mendoza was consistent and credible enough to establish petitioners’ guilt beyond reasonable doubt.