PEOPLE v.

BADILLA
G.R. No. 218578; 17 AUG. 2016
(Ponente: Peralta, J.)

FACTS:
On Sept. 6, 2010 PO2 Paras received a call from a concerned citizen about
indiscriminate gun fire at the BMBA compound, 4th avenue, Caloocan City. Along with is
fellow officers, PO2 Paras arrived at the area to find accused Badilla standing in an
alley. PO2 Paras immediately introduced himself as a police officer after seeing Badilla
suspiciously pulling or drawing something from the latter’s pocket. Badilla was pulled in
the arm and asked to bring out his hand finding therein plastic sachet of crystalline
substance. The substance was confiscated by PO2 Paras while Badilla was informed of
his rights before arrest. Badilla and the confiscated sachet were brought to the SAID-
SOTG where PO2 Paras marked the sachet. Badilla and the sachet were turned-over to
PO2 Espadero who put the sachet in a bigger re-marked plastic sachet. The sachet and
a request for drug test on the urine sample of Badilla was prepared and subsequently
approved by P/Chief Insp. Tarnate. PO2 Espadero transmitted the item to PO1 Pataweg
at Northern Police District Crime Laboratory Office who later the same to P/Sr. Insp.
Libres for examination. Tests showed the substance to be shabu and the urine sample
positive for the same. The items were re-marked by P/Sr. Insp. Libres deposited them to
the evidence custodian and later retrieved for presentation in court.
Badilla as sole witness argued that on Sept. 6, 2016 he was called by PO2 Paras
whom he knows as a police officer who frequents the area. He claimed that the latter’s
companion poked a gun at him which he shoved away, falling to the ground. He further
claims that he was arrested and told that he will be charged a non-bailable offense, and
that he only saw the plastic sachet of shabu in court. He claimed that police officers
asked for Php 20,000.00, but he refused. He also claimed that no drug test was made.
The RTC found Badilla guilty and sentenced him to 20 years and 1 day to life
imprisonment and a fine of Php 400,000.00. Badilla’s appeal at the CA was denied, but
the modified the term of imprisonment to 20 years and 1 day only.

ISSUE:
Whether or not the seized shabu is admissible as evidence.

RULING:
The conviction is valid because the shabu presented in court was shown to be
the same that was seized when Badilla was arrested. The chain of custody rule was not
violated because the rule on chain of custody requires that the persons who handled the
confiscated illegal drugs to be identified for purposes of duly monitoring movement of
evidence until presentation in court. Facts show that the confiscated sachet was
properly monitored and the persons handling it were duly identified. Integrity and
evidentiary value of the confiscated drug was not compromised because the chain of
custody was properly shown. Substantial compliance to the chain of custody
requirement is sufficient to prove integrity and evidentiary value so long as the seized
item marked at the police station is identified as the same presented in court.

SUBJECT: RA 9165; PROOF OF IDENTITY AND INTEGRITY OF SEIZED

EVIDENCE

TL; DR: THE EVIDENCE CONVICTING BADILLA IS VALID EVEN IF SCTRICT

COMPLIANCE TO THE CUSTODIAL REQUIREMENTS OF THE LAW
WAS NOT FOLLOWED BECAUSE SAID CONFISCATED SHABU WAS
SHOWN TO BE THE SAME EVIDENCE PRESENTED IN COURT.