People v. Mateo
REITERATIONFacts
The Antecedents: The accused-appellant, Jinggoy Mateo y Rodriguez, was indicted for violation of Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) for allegedly selling one (1) transparent plastic sachet of white crystalline substance containing 0.20 gram of Methylamphetamine Hydrochloride. The prosecution presented evidence that a buy-bust operation was conducted by PO2 Joseph Ortiz, who posed as the buyer. PO2 Ortiz testified that he was introduced to the accused-appellant by an informant, and after stating his intention to buy shabu worth ₱200.00, the accused-appellant handed him a plastic sachet in exchange for the marked bill. PO2 Ortiz then gave the pre-arranged signal, after which he and his team arrested the accused-appellant. The seized sachet was marked, sealed, and turned over to the investigator. Procedural History: The Regional Trial Court (RTC) of Quezon City, Branch 103, found the accused-appellant guilty beyond reasonable doubt and sentenced him to life imprisonment and a fine of ₱500,000.00. The RTC gave credence to the prosecution's evidence and found no reason to doubt the regularity of the buy-bust operation. The Court of Appeals affirmed the RTC's decision, upholding the conviction and finding no error in the RTC's appreciation of facts and evidence. The accused-appellant then appealed to the Supreme Court. The Petition: The accused-appellant argued that the arresting officers failed to comply with the requirements for the proper custody of seized dangerous drugs under Section 21 of R.A. 9165, specifically the conduct of a physical inventory and photographing of the seized items in the presence of required witnesses. He also claimed that the integrity and evidentiary value of the seized drug were not preserved.
Issue(s)
Whether the arresting officers' alleged non-compliance with Section 21 of R.A. 9165 renders the seized dangerous drug inadmissible in evidence. Whether the integrity and evidentiary value of the seized dangerous drug were properly preserved. Whether the accused-appellant was guilty beyond reasonable doubt of the illegal sale of dangerous drugs.
Ruling
The Supreme Court denied the appeal and affirmed the decision of the Court of Appeals, upholding the conviction of the accused-appellant for violation of Section 5, Article II of Republic Act No. 9165. The Court imposed the penalty of life imprisonment and a fine of ₱500,000.00.
Ratio Decidendi
On the alleged non-compliance with Section 21 of R.A. 9165: The Court reiterated that non-compliance with Section 21 of R.A. 9165, particularly the requirements for physical inventory and photographing of seized drugs, does not render the evidence inadmissible. This issue was raised for the first time on appeal, and the Court has consistently held that objections to admissibility of evidence must be made at the earliest opportunity, which is before the trial court. The primary concern is the preservation of the integrity and evidentiary value of the seized items, not strict adherence to procedural steps if substantial compliance or justifiable grounds exist. The Court cited previous rulings in People v. Norberto del Monte y Gapay @ Obet and People v. Pringas to support this position, emphasizing that evidence is admissible if relevant and not excluded by law or rules, and that the Rules of Court prioritize admissibility unless specifically excluded. On the preservation of the integrity and evidentiary value of the seized dangerous drug: The Court found that the integrity and evidentiary value of the seized drug were properly preserved. The specimen was adequately marked with the initials "JO," dispatched to the Crime Laboratory, and subjected to forensic examination, which yielded a positive result for methylamphetamine hydrochloride. The accused-appellant stipulated to the Chemistry Report and the findings of the forensic chemist. Furthermore, the accused-appellant did not challenge the custody, disposition, or preservation of the seized items before the RTC or the Court of Appeals, making his objection on appeal too late. The Court emphasized that the corpus delicti, the prohibited drug, was sufficiently established through the positive Chemistry Report and the stipulation of facts. On the guilt of the accused-appellant for illegal sale of dangerous drugs: The Court found that all the necessary elements for the prosecution of the illegal sale of drugs were established beyond reasonable doubt. These elements include the identities of the buyer and seller, the object of the sale, the consideration, the delivery of the thing sold, and the payment therefor. PO2 Ortiz positively identified the accused-appellant as the seller, and his testimony was corroborated by the physical evidence and the stipulation of facts. The Court also upheld the presumption of regularity in the performance of official duties by the police officers involved in the buy-bust operation, as the accused-appellant failed to present clear and convincing evidence to overturn this presumption. The Court found no indication that the police officers were improperly motivated or failed to perform their duties regularly. The Court concluded that the accused-appellant was caught in flagrante delicto during a valid buy-bust operation.
Main Doctrine
Non-compliance with Section 21 of R.A. 9165, particularly regarding the physical inventory and photographing of seized drugs, does not render the drugs inadmissible in evidence as long as the integrity and evidentiary value of the seized items are properly preserved. Objections to the admissibility of evidence based on alleged lapses in safekeeping must be raised before the trial court and cannot be raised for the first time on appeal.