People of the Philippines vs Anita Miranda y Beltran

G.R. No. 205639

Facts:

Appellant was charged before the RTC of Calapan City, Oriental Mindoro with the violation of
Comprehensive Dangerous Drugs Act of 2002. She pleaded not guilty during arraignment. During the
trial the prosecution established that after the a surveillance outside the appellants house located in
Barangay Ibaba West, of Calapan City, it was confirmed that she was engaged in the sale of shabu. Thus,
the police formed a buy-bust team. Then the buy-bust team went to Barangay Ibaba West and one
member of the team PO2 Rodil proceeded to the appellants house, while the rest of the team hid
somewhere near appellants house. PO2 Rodil saw the appellant outside her house and after a brief
conversation, told her that she was buying shabu. The Appellant then went inside her house and upon
her return, handed to PO2 Rodil one transparent plastic sachet containing white crystalline substance.
After the payment of the marked money they proceeded in arresting the appellant. Then the team
informed Barangay Councilor of the Barangay, about the operation and they all brought appellant to
Calapan Police Station. Both Inventory of the seized item and the taking of appellants photos were made
at the police station. The seized items are marked and submitted the same for laboratory examination on
the same day. The specimen submitted is positive for shabu.

Ruling of the RTC

Guilty beyond reasonable doubt as principal of the crime charged in the aforequoted information and
default of any modifying circumstances attendant, hereby sentences her to life and a fine of Five
Hundred Thousand.

Ruling of the CA

Court of Appeals denied the her appeal and affirmed the RTC decision in toto.

Dissatisfied, the appellant seek for the reversal of her conviction. The parties required to submit their
Supplemental briefs if they desire. Appellant filed her Supplemental Brief, while the OSG did not.

Issue:

Whether or not the item presented in court was the very item seized from her at the time of her arrest.

Ruling:

The SC finds no merit in this appeal.

It is material in every prosecution for the illegal sale of a prohibited drug that the drug, which
the corpus delicti, be presented as evidence in the court. Hence, the identity of the prohibited drug must
be established without any doubt. Even more than this, what must be established is the fact that the
substance bought during the buy-bust operation is the same substance offered in court as exhibit. The
chain of custody requirement performs this function in that it ensures that unnecessary doubts
concerning the identity of the evidence are removed.

In this case, the SC finds that the prosecution was able to establish the crucial links in the chain
of custody of the seized sachet of shabu.