G.R. No. 236023 - Badio y Dicampung vs. People

The case involves a petition for review on certiorari filed by Macacuna Badio y Dicampung, challenging the decisions of the Court of Appeals (CA) and the Regional Trial Court (RTC) regarding his conviction for Illegal Possession of Dangerous Drugs under Republic Act No. 9165.
The RTC found Badio guilty and sentenced him to imprisonment for an indeterminate period of twelve years and one day to seventeen years and four months, along with a fine of P300,000.00.
The CA modified the RTC's decision, increasing the prison term to twenty years and one day and raising the fine to P400,000.00.

The prosecution's case stemmed from a tip received by the Moriones, Tondo Police Station regarding an impending illegal drug transaction.
On August 24, 2013, police officers observed Badio engaging with passengers of a vehicle and allegedly displaying two plastic sachets containing a white crystalline substance.
Upon police intervention, Badio discarded the sachets but was apprehended, and the sachets were recovered.
A subsequent search revealed another sachet in Badio's possession, and all three sachets were marked, photographed, and inventoried in the presence of a media representative.
The seized items tested positive for methamphetamine hydrochloride (shabu), weighing a total of 5.01 grams.

Badio denied the charges, claiming he was unlawfully arrested by unidentified men who identified themselves as police officers while he was in a parked vehicle at a restaurant.
He contended that he was unaware of the drug charges until after his arrest.

The RTC found the prosecution's evidence sufficient to establish Badio's guilt beyond reasonable doubt, emphasizing the unbroken chain of custody of the seized drugs.
The court gave credence to the testimonies of the prosecution witnesses, presuming they performed their duties regularly.

The CA affirmed the RTC's ruling with modifications, emphasizing the sufficiency of PO3 Jimenez's testimony in convicting Badio.
The CA acknowledged procedural lapses in the inventory process but concluded that the integrity of the evidence was preserved through the established chain of custody.

The Supreme Court found merit in Badio's appeal, emphasizing the necessity of establishing the identity of the dangerous drug with moral certainty.
The Court reiterated that the prosecution must account for each link in the chain of custody, including immediate marking, inventory, and photography of the seized items.

The law mandates that the inventory and photography of seized items must be conducted in the presence of the accused and certain witnesses, including representatives from the media and the DOJ.
The Court recognized that while strict compliance is generally required, deviations may be excused if the prosecution can demonstrate justifiable grounds for non-compliance and that the integrity of the evidence was preserved.