### Facts:
1. **Initial Charges (March 30, 2014):** Peter Lopez y Canlas (Lopez) was charged with illegal sale (Criminal Case No. IR-10559) and use of dangerous drugs (Criminal Case No. IR-10614) under Sections 5 and 15, respectively, of Republic Act (R.A.) No. 9165.
2. **Illegal Sale (Section 5):** Lopez allegedly sold a 0.193-gram sachet of methamphetamine hydrochloride (shabu) to PO1 Jonard B. Buenaflor during a buy-bust operation in San Francisco, Iriga City. The operation involved marked money totaling Php2,000.
3. **Illegal Use (Section 15):** After arrest, Lopez’s urine tested positive for methamphetamine, per Chemistry Report No. DTC-081-2014. The charge was based on this test result following his arrest from the buy-bust operation.
4. **Arraignment:** Lopez pleaded not guilty to both charges. A trial on the merits ensued.
5. **Prosecution’s Case:** The prosecution narrated that PO1 Buenaflor, acting as a poseur-buyer, successfully performed a buy-bust operation. After Lopez handed over the shabu and received the marked money, he was arrested. The seized items were inventoried and photographed in the presence of DOJ, media, and Barangay officials, ensuring chain-of-custody compliance.
6. **Defense’s Case:** Lopez denied the allegations, claiming he was framed. He asserted he was merely flagged down by police, was unlawfully detained, and that the drugs were planted on him.
7. **RTC Ruling:** Lopez was found guilty beyond reasonable doubt for both charges. Sentences:
– **Illegal Sale (Section 5):** Life imprisonment and a fine of Php500,000.
– **Illegal Use (Section 15):** Minimum of six months rehabilitation.
8. **Appeal to CA:** Lopez appealed the RTC decision, arguing flaws in the buy-bust operation, including the absence of prior surveillance and inconsistencies in the testimonies.
9. **CA Ruling:** CA affirmed RTC’s decision, validating the conducted procedures and dismissing Lopez’s defense of denial and frame-up.
10. **Appeal to Supreme Court:** Lopez challenged the CA’s affirmation of his conviction.
### Issues:
1. **Was the conviction valid for illegal sale of dangerous drugs under Section 5, Article II, R.A. No. 9165?**
2. **Was the conviction valid for illegal use of dangerous drugs under Section 15, Article II, R.A. No. 9165?**
3. **Were the procedural and custodial protocols during the buy-bust operation consistent with the law?**
4. **Did the prosecution sufficiently establish the identity and integrity of the dangerous drugs as corpus delicti?**
### Court’s Decision:
1. **Illegal Sale (Section 5):** The Supreme Court found the guilt of Lopez for illegal sale of dangerous drugs as sufficiently proven:
– **Elements of Illegal Sale:** Court evidenced proper transaction of the sale via PO1 Buenaflor’s testimony, marked money, and corroborative documents.
– **Chain of Custody:** The seized item followed rigorous chain-of-custody protocols, complying strictly with Section 21 of R.A. No. 9165.
2. **Illegal Use (Section 15):** Lopez’s conviction was reversed due to procedural shortcomings:
– **Confirmatory Test Requirement:** The Court found an inadequacy as only a screening test (TLC) was conducted and confirmed as positive. No subsequent confirmatory test was shown as having been conducted, rendering the sole Chemistry Report No. DTC-081-2014 legally insufficient to validate a conviction.
### Doctrine:
1. **Chain-of-Custody Rule:** Compliance with Section 21 of R.A. No. 9165 ensures the integrity of confiscated drugs. Any deviation must have justifiable grounds while still preserving the component’s integrity.
2. **Necessity of Confirmatory Test:** As established under Sections 15 and 36 of R.A. No. 9165, initial positive results from drug screening tests must be confirmed via a secondary, more specific analytical process. Failure to conduct a confirmatory test is fatal to the conviction for illegal drug use.
### Class Notes:
– **Elements of Illegal Drug Sale:**
– Identity of buyer, seller, object, and consideration.
– Delivery and payment.
– (Verbatim) R.A. No. 9165, Sec. 5.
– **Chain of Custody:**
– Seizure, inventory, and photographing processes.
– Insulated witnesses required at the seizure.
– (Verbatim) R.A. No. 9165, Sec. 21.
– **Screening and Confirmatory Tests:**
– R.A. No. 9165, Sec. 15, and Sec. 36.
– Confirmatory test necessary for prosecution.
### Historical Background:
This case is situated within the broader enforcement of R.A. No. 9165, enacted in 2002 to reinforce the Philippines’ commitment to a drug-free society via stringent legal measures. It underscores the judiciary’s ongoing challenge to balance rigorous law enforcement while upholding fundamental procedural rights under due process.
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