People v. Alcala
REITERATIONFacts
The Antecedents: An informant reported the illegal drug activities of an individual known as alias Joy in Quezon City. A buy-bust team was formed, with PO2 Erwin Bautista designated as the poseur-buyer. The team proceeded to the target area, and the informant introduced PO2 Bautista to alias Joy, later identified as appellant Joy Alcala. PO2 Bautista inquired about purchasing shabu, and upon agreeing on a ₱100.00 price, Alcala retrieved a plastic sachet containing white crystalline substance from her pocket. PO2 Bautista handed over the marked ₱100.00 bill, and Alcala gave him the sachet. PO2 Bautista then gave a pre-arranged signal, leading to Alcala's arrest. The marked money was recovered from her. The seized sachet was marked and submitted for laboratory examination, which confirmed the presence of methylamphetamine hydrochloride (shabu). Procedural History: The Regional Trial Court (RTC), Branch 82 of Quezon City, found Joy Alcala guilty beyond reasonable doubt for violation of Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). The RTC sentenced her to life imprisonment and a fine of ₱500,000.00. The Court of Appeals (CA) affirmed the RTC's decision. The Petition: The accused-appellant appealed to the Supreme Court, raising the issue of whether the prosecution failed to establish the chain of custody and integrity of the alleged seized illegal drugs due to non-compliance with Section 21 of R.A. No. 9165, thereby failing to prove her guilt beyond reasonable doubt.
Issue(s)
Whether the RTC and the CA erred in finding that the evidence of the prosecution was sufficient to convict the accused of the alleged sale of methamphetamine hydrochloride or shabu, in violation of Section 5 of R.A. No. 9165. Whether the prosecution failed to establish the chain of custody and integrity of the alleged seized illegal drugs for failure to comply with the mandatory procedures under Section 21 of R.A. No. 9165.
Ruling
The appeal is DISMISSED. The Court of Appeals Decision affirming the RTC's Decision is AFFIRMED in all respects.
Ratio Decidendi
On the sufficiency of evidence for conviction of illegal sale of dangerous drugs: The Court reiterated the elements for the successful prosecution of illegal sale of drugs under Section 5, Article II of R.A. No. 9165, which are: (1) the identity of the buyer and seller, object and consideration; and (2) the delivery of the thing sold and the payment therefor. The Court found that these elements were sufficiently established by the prosecution. PO2 Bautista testified to the actual exchange of the marked money for the prohibited drug, and the accused's question, "iiskor kayo, magkano?" indicated her knowledge that she was selling an illegal substance. The corpus delicti, the subject drug, was seized, marked, and identified as a prohibited drug. The Court gave credence to the testimonies of the police officers, who are presumed to have performed their duties regularly, absent any evidence of ill motive. The accused's bare denial, unsubstantiated by credible evidence, was considered weak and could not prevail over the positive testimonies of the prosecution witnesses and the physical evidence. On the failure to establish the chain of custody and integrity of the seized illegal drugs due to non-compliance with Section 21 of R.A. No. 9165: The Court acknowledged that strict compliance with the procedures in Section 21 of R.A. No. 9165, such as immediate marking and inventory, was not fully observed. However, the Court emphasized that failure to strictly comply with these procedures does not render the arrest illegal or the seized items inadmissible. What is essential is the preservation of the integrity and evidentiary value of the seized items. The Court found that the chain of custody in this case was unbroken. The drug seized from the accused was accounted for from the moment of arrest, during transport to the police station, and its submission to the crime laboratory. The police officers identified the seized drug with certainty when presented in court, and there were no conflicting testimonies or inconsistencies that would cast doubt on its integrity. The Court cited jurisprudence holding that the issue of non-compliance with Section 21 is one of weight, not admissibility, and that the integrity of the evidence was preserved under the circumstances.
Main Doctrine
The prosecution must prove the elements of illegal sale of dangerous drugs, namely: (1) the identity of the buyer and seller, object and consideration; and (2) the delivery of the thing sold and the payment therefor. While strict compliance with Section 21 of RA 9165 regarding inventory and photographing of seized drugs is ideal, failure to do so does not render the evidence inadmissible if the integrity and evidentiary value of the seized items are preserved, and the chain of custody is unbroken.