People v. Lapasaran
REITERATIONFacts
The Antecedents: The accused-appellant, Renato Lapasaran y Medinilla a.k.a. "Mao," was arrested following a buy-bust operation conducted on September 12, 2006, in Taguig City. The operation was based on informant reports of his alleged illegal drug activities. During the operation, PO1 Alexander Saez acted as the poseur-buyer and purchased suspected shabu for ₱200.00, receiving one heat-sealed transparent plastic sachet marked "RML." The accused-appellant also allegedly showed PO1 Saez another sachet, which was confiscated and marked "RML-1." Upon the pre-arranged signal, PO2 Emmanuel Maglana arrested the accused-appellant and recovered the marked bills and the second sachet. Procedural History: Two separate informations were filed charging the accused-appellant with illegal possession and illegal sale of methamphetamine hydrochloride (shabu) in violation of Sections 11(3) and 5(1), Article II of Republic Act No. 9165. The Regional Trial Court (RTC), Branch 267, Pasig City, found the accused-appellant guilty beyond reasonable doubt of both charges and sentenced him to twelve (12) years and one (1) day to twenty (20) years imprisonment and a fine of ₱300,000.00 for illegal possession, and life imprisonment and a fine of ₱500,000.00 for illegal sale. The Court of Appeals (CA) affirmed the RTC decision in toto. The accused-appellant appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt due to non-compliance with Section 21, Article II of RA 9165 and the chain of custody rule. The Petition: The accused-appellant reiterates his argument that the prosecution failed to prove beyond reasonable doubt the corpus delicti of the offenses due to the alleged non-compliance with the chain of custody rule under Section 21, Article II of Republic Act No. 9165.
Issue(s)
Whether the prosecution sufficiently established the chain of custody of the seized dangerous drugs. Whether the accused-appellant was guilty beyond reasonable doubt of illegal possession and illegal sale of dangerous drugs.
Ruling
The appeal is DENIED. The Decision of the Court of Appeals affirming the RTC decision is AFFIRMED.
Ratio Decidendi
On the chain of custody and corpus delicti: The Supreme Court held that the prosecution successfully established the chain of custody of the seized dangerous drugs. The Court noted that the seized items were marked "RML" and "RML-1" immediately after seizure. These were then turned over by the apprehending officers to the investigating officer, P/SInsp. Obong, who subsequently delivered them to the PNP Crime Laboratory for examination. The Physical Science Report confirmed that the substances tested positive for shabu. Finally, the sachets were presented in court. The Court emphasized that while strict compliance with Section 21 of RA 9165 is required, non-compliance may be excused if the integrity and evidentiary value of the seized items are properly preserved, which was demonstrated in this case through the marking, turnover, laboratory examination, and presentation in court. The Court found no doubt that the chain of custody rule was duly followed, thereby preserving the integrity of the corpus delicti. On the guilt of the accused-appellant: The Supreme Court affirmed the findings of the RTC and the CA that the accused-appellant was guilty beyond reasonable doubt of both illegal possession and illegal sale of dangerous drugs. The Court reiterated the principle that in drug-related cases, credence is given to the testimonies of police officers who conducted the buy-bust operation, as they are presumed to have performed their duties regularly, absent evidence of ill motive. The accused-appellant failed to present any evidence to show that the police officers had any reason to falsely implicate him. Therefore, the prosecution successfully proved the elements of both offenses.
Main Doctrine
The prosecution must establish the chain of custody of the seized dangerous drugs to preserve their integrity and evidentiary value. Non-compliance with Section 21 of RA 9165 may be excused if the integrity and evidentiary value of the seized items are properly preserved.