Facts:

The case involves Jerry Barayuga y Joaquin (petitioner) as the accused against the People of the Philippines (respondent). The events leading to the case transpired on May 30, 2012, in Laoag City, where the petitioner was charged with the illegal sale of methamphetamine hydrochloride, commonly known as shabu, in violation of Section 5 of Republic Act 9165. The prosecution's case was built around a buy-bust operation conducted by police officers, including PO1 Jackson Sugayen, SPO4 Rovimanuel Balolong, and SPO1 Jonathan Alonzo. During the operation, a police asset arranged to buy shabu from the petitioner, who was allegedly caught in the act of selling a heat-sealed plastic sachet containing 0.0803 grams of shabu for P1,000.00.

The trial court found the petitioner guilty and sentenced him to life imprisonment and a fine of P500,000.00. The trial court acknowledged some lapses in the chain of custody regarding the marking and inventory of the seized items but concluded t...

Facts:

The Charge

Petitioner Jerry Barayuga y Joaquin was charged with violating Section 5 of Republic Act No. 9165 (RA 9165) for the sale of 0.0803 gram of methamphetamine hydrochloride (shabu) on May 30, 2012, in Laoag City. The prosecution alleged that he sold the illegal drug to a police poseur-buyer without any license or authority.

The Prosecution's Evidence

1. PO1 Jackson Sugayen testified that he acted as the poseur-buyer in a buy-bust operation. He handed petitioner P1,000.00 in marked money, and in exchange, petitioner gave him a plastic sachet containing shabu. After the transaction, petitioner was arrested, and the marked money and a fliptop cigarette box were recovered from him.
2. SPO4 Rovimanuel Balolong corroborated PO1 Sugayen's testimony, stating that he coordinated the operation and acted as backup during the arrest.
3. The prosecution also presented forensic chemist P/Insp Amiely Ann Navarro, who confirmed that the substance in the sachet tested positive for methamphetamine hydrochloride.

The Defense's Evidence

Petitioner denied the charges, claiming that he was falsely arrested. He testified that he was on his way to play mahjong when he was stopped by two men, one of whom was PO1 Sugayen. He alleged that the police planted the evidence and forced him to pose with the seized items for photographs.

Trial Court's Ruling

The trial court found petitioner guilty beyond reasonable doubt of illegal sale of shabu and sentenced him to life imprisonment and a fine of P500,000.00. The court acknowledged lapses in the chain of custody but ruled that the integrity of the seized drug was preserved.

Court of Appeals' Ruling

The Court of Appeals affirmed the trial court's decision, holding that the prosecution proved all elements of the crime and that the chain of custody was sufficiently established despite minor lapses. The court also noted that petitioner failed to file a notice of appeal within the reglementary period, leading to the issuance of an entry of judgment.

Issue:

1. Did the Court of Appeals err in finding no compelling reason to lift the entry of judgment in CA-G.R. CR HC No. 07395?
2. Did the arresting police officers comply with the chain of custody rule under Section 21 of RA 9165?

Ruling:

The Supreme Court granted the petition and acquitted petitioner Jerry Barayuga y Joaquin.

1. Relaxation of Procedural Rules: The Court relaxed the procedural rules to serve the broader interests of justice. Petitioner's counsel's gross negligence in failing to file a notice of appeal deprived him of the opportunity to challenge his conviction. The Court emphasized that technicalities should not obstruct substantial justice, especially in cases involving life imprisonment.

2. Chain of Custody Rule: The Court found that the arresting officers failed to comply with the chain of custody rule under Section 21 of RA 9165. Specifically:

   • The marking of the seized drug was not done at the place of arrest, and no insulating witnesses (media, DOJ representative, or elected public official) were present during the marking, inventory, or photographing of the evidence.
   • The prosecution failed to justify these lapses, casting serious doubt on the integrity and identity of the seized drug.

The Court ruled that the lapses in the chain of custody were fatal to the prosecution's case, as they undermined the integrity of the corpus delicti. Consequently, petitioner's acquittal was warranted.

Ratio:

1. Relaxation of Procedural Rules: The Court may relax procedural rules in exceptional cases to serve the broader interests of justice, especially when the negligence of counsel results in serious injustice to the accused.
2. Chain of Custody in Drug Cases: Strict compliance with the chain of custody rule under Section 21 of RA 9165 is essential to ensure the integrity and evidentiary value of seized drugs. Non-compliance, without justifiable grounds, renders the evidence inadmissible and warrants acquittal.
3. Presumption of Regularity vs. Presumption of Innocence: The presumption of regularity in the performance of official duty cannot prevail over the presumption of innocence when there are clear lapses in the chain of custody.

Disposition

The Supreme Court reversed the Court of Appeals' decision and acquitted petitioner Jerry Barayuga y Joaquin. The Court ordered his immediate release unless he is being held for another lawful cause.