Facts:

• The case involves the accused, Efren Ditona, who was charged with selling and possessing illegal drugs, violation of the Omnibus Election Code, and illegal possession of firearms.
• On July 19, 2002, during the election period, a buy-bust operation was conducted at Compound 7-9th Street, Barangay Ilalim, Olongapo City.
• SPO1 Alfredo Flores acted as a poseur-buyer and gave the accused marked money in exchange for one plastic sachet of shabu.
• Before the police officers could apprehend Ditona, he noticed their movement and ran into his house.
• The officers arrested Ditona in his house along with four others who were sniffing shabu and preparing aluminum tin foils.
• The police found the marked money, transparent plastic sachets containing suspected shabu, and a gun with live ammunition.
• The substance in the sachets tested positive for methamphetamine hydrochloride or shabu.

Issue:

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Ruling:

• The court ruled that the prosecution failed to establish the required chain of custody of the seized drugs, leading to the acquittal of the accused on drug-related charges.
• However, the ...(Unlock)

Ratio:

• For the prosecution to successfully prosecute an accused for selling illegal drugs, they must prove the identities of the buyer and the seller, the object, the consideration, and the delivery of the thing sold and the payment for it.
• Similarly, for an accused to be convicted of possession of illegal drugs, the prosecution must prove that the accused was in possession of the prohibited drug, such possession is not authorized by law, and the accused freely and consciously possessed the prohibited drug.
• Additionally, the prosecution must prove the corpus delicti, the body of the crime, by establishing the chain of custody of the seized drugs.
• In this case, the prosecution failed to prove the corpus delicti as there were substantial gaps in the chain of custody of the seized drugs, raising doubts on the authenticity of the evidence presented in court.
• The police officers did not provide details on how they handled the seized drugs from the time they frisked Ditona until they brought him to the police station.
• They also failed to specify what things were confiscated from Ditona.
• The witnesses did not adequately describe the movements of the seized drugs, and there was no evidence of how the drugs reached the laboratory technician and were stored pending turnover to the court.
• Therefore, the court concluded that the prosecution failed to establish the required chain of custody of the seized drugs, and doubts on the authenticity of the evidence arose...continue reading