Title
People vs. Abdul
Case
G.R. No. 186137
Decision Date
Jun 26, 2013
A buy-bust operation led to appellant's arrest for drug sale; acquitted due to chain-of-custody lapses casting doubt on evidence integrity.
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Case Digest (G.R. No. 186137)

Facts:

Background and Incident Details

On 25 June 2005, Police Officer 2 Daniel E. Akia (PO2 Akia) of the Philippine Drug Enforcement Agency-Cordillera Administrative Region (PDEA-CAR) received a tip from an informant about the illegal drug activities of Datu Not Abdul (appellant). A buy-bust operation was planned, with PO2 Akia posing as the buyer. The operation took place in San Vicente, Baguio City, where appellant allegedly sold a medium-sized, transparent, heat-sealed plastic sachet containing a white crystalline substance (shabu) to PO2 Akia for ₱6,500. Upon realizing the money was fake, appellant was apprehended.

Arrest and Post-Operation Procedures

After the arrest, appellant was brought to the PDEA office, where an inventory of the seized item was conducted in the presence of representatives from the Department of Justice (DOJ), the media, and the barangay council. The plastic sachet was marked with initials and forwarded to the PNP Regional Crime Laboratory for analysis. The forensic chemist confirmed the substance was methamphetamine hydrochloride (shabu).

Trial Proceedings

Appellant pleaded not guilty during arraignment. The prosecution presented testimonies from the arresting officers and submitted the seized drug and chemistry report as evidence. Appellant, in his defense, claimed he was framed and extorted by the police. The Regional Trial Court (RTC) found appellant guilty of violating Section 5, Article II of Republic Act No. 9165, sentencing him to life imprisonment and a ₱500,000 fine. The Court of Appeals (CA) affirmed the RTC’s decision.


Issue:

The sole issue before the Supreme Court was whether the prosecution sufficiently established compliance with the chain-of-custody rule to ensure the integrity of the confiscated drug evidence.


Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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