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PEOPLE v. JONATHAN VISTRO Y BAYSIC

FACTS:

On June 4, 2009, a buy-bust operation was conducted by Philippine Drugs Enforcement Agency (PDEA) officers in Pangasinan to apprehend the appellant, Jonathan Vistro, who was suspected of selling shabu. Intelligence Officer Jaime Clave was designated as the poseur-buyer and was given marked money. Upon arrival at the target area, Clave was introduced to Vistro by a police asset. Vistro handed Clave a sachet of shabu in exchange for the marked money. When the transaction was consummated, another officer, Noreen Bautista, rushed to the scene and arrested Vistro. The marked money was recovered from Vistro's possession. Meanwhile, the barangay captain and other barangay officials were discovered to be relatives of Vistro, so the buy-bust team withdrew from the area. Upon arrival at the PDEA office, the seized shabu was marked and a Certificate of Inventory was prepared in the presence of Vistro. The sachet of shabu was then sent to the police crime laboratory for examination. Vistro denied the charges and claimed that he was falsely accused by the PDEA officers, who were looking for his parents. The Regional Trial Court (RTC) found Vistro guilty of violating RA 9165, while his co-accused, Teresita Baysic, was acquitted. The Court of Appeals affirmed the RTC's decision. Vistro appealed his conviction to the Supreme Court.

ISSUES:

  1. Whether or not the prosecution was able to establish the guilt of the appellant beyond reasonable doubt for violation of Section 5, Article II of R.A. 9165.

RULING:

  1. The court ruled that the prosecution was able to establish the guilt of the appellant beyond reasonable doubt. The testimonies of the PDEA officers established the crucial links in the chain of custody of the seized shabu. Non-compliance with Section 21, Article II of R.A. 9165 and Section 21(a) of its Implementing Rules and Regulations is not fatal to the prosecution's case as long as the integrity and evidentiary value of the seized shabu are preserved.

PRINCIPLES:

  • Non-compliance with Section 21, Article II of R.A. 9165 and Section 21(a) of its Implementing Rules and Regulations is not fatal to the prosecution's case as long as the integrity and evidentiary value of the seized items are preserved.

  • The chain of custody of seized items should be established to ensure their integrity and evidentiary value.