Statement of the Issues

1. WON prosecution proved with unwavering exactitude the chain of custody.

a. WON testimony of Mordeno, the police officer who allegedly marked the sachets of shabu and delivered the same to the laboratory, is indispensable to establish the rule on the chain of custody beyond reasonable doubt.

i.. IT IS NEEDED. People v Sitco: failure to offer the testimony of key witnesses to establish a sufficiently complete chain of custody of a specimen of shabu, and the irregularity which characterized the handling of the evidence before it was finally offered in court, fatal t case.

ii. People v Obminaris - Police officer was able to observe the uniqueness and to acknowledge the marking as his own

iii. Feeble daw ang excuse ni Amora -- should have presented the physician. “Sometimes” shows na not suffered total memory loss.

b. WON police officers faithfully complied with the procedure set forth in RA 9165.

i. Mandatory to comply faithfully to procedure to safeguard against potential abuses by law enforcement agents

ii. In this case, no showing that photos were taken in presence of appellant, representative of media, and representative of DOJ

2. WON prosecution proved the elements of sale and possession of illegal drugs beyond reasonable doubt.

ii. Elements to be proven: (1) identities of buyer and seller, the object, and the consideration; the delivery of the thing sold and the payment therefor