Facts:
On
April 21, 2014, the
Second Division of the Supreme Court reviewed the
February 8, 2008 decision of the
Court of Appeals in
CA-G.R. CR. H.C. No. 02726, which had affirmed the
January 29, 2007 judgment of the
Regional Trial Court, Branch 82, Quezon City, finding
Sonny Sabdula y Amanda guilty beyond reasonable doubt of violating
Section 5, Article II of
R.A. No. 9165 and sentencing him to
life imprisonment. The RTC conviction was based on an Information alleging that on or about
February 1, 2004 in
Quezon City, the accused, not being authorized by law to sell, dispense, deliver, transport, or distribute dangerous drugs, did willfully and unlawfully sell, dispense, deliver, transport, distribute, or act as broker in the transaction involving
0.10 gram of white crystalline substance containing
methylamphetamine hydrochloride (shabu) in exchange for
P200.00. At trial, the prosecution presented
PO2 Bernard Centeno and relied on stipulated testimonies of
PO3 Joselito Chantengco and
PO1 Alan Fortea. The defense presented the accused and
Shirley Sabdula. The prosecution evidence showed that in the morning of
February 1, 2004, a confidential informant reported to members of the
Central Police District (CPD) in
Baler, Quezon City the illegal drug activities of a person alias
“Moneb” at a squatter’s area in
San Roque II, Quezon City. Acting on the tip, operatives formed a
buy-bust team with
PO2 Centeno as the poseur-buyer. Around
7:00 p.m., the team and the informant went to the target area where the informant introduced
PO2 Centeno to the accused as his “kumpare.”
PO2 Centeno asked the accused for “two hundred pesos worth of shabu,” and the accused allegedly took out a plastic sachet, handed it to
PO2 Centeno, and then received the pre-arranged
P200.00. After the signal,
PO2 Centeno identified himself as a police officer and arrested the accused. He frisked the accused and recovered the buy-bust money from his right pocket. The team then brought the accused to
Baler Police Station 2.
PO2 Centeno turned over the seized plastic sachet to
SPO2 Salinel, who passed it to
PO3 Chantengco, who requested laboratory examination, with
PO2 Centeno bringing both the seized item and the request to the
Central Police District Crime Laboratory. The Chemistry Report,
No. D-140-2004, showed that the specimen tested positive for methylamphetamine hydrochloride. The accused denied the charge and asserted that on
January 29, 2004 between
8:00 p.m. and 9:00 p.m., he was in a taxi at
C5 Road, Fort Bonifacio, Taguig City when a group of armed men made him leave the vehicle, brought him to
Baler Police Station, confiscated items from him, and informed him that he would be detained for drug charges for
40 years. Shirley’s testimony, as summarized by the RTC, described a request for money as ransom for her brother, implying detention by police officers due to her alleged failure to give the demanded amount. Despite the CA’s affirmance, the Supreme Court reversed and acquitted the accused because the prosecution failed to prove the elements of the crime beyond reasonable doubt, focusing on deficiencies in the
custodial link—particularly the absence of evidence of immediate
marking, and the failure to show compliance with statutory requirements on inventory and photography in the presence of required witnesses—creating reasonable doubt on the identity and integrity of the corpus delicti.
Issues:
Whether the prosecution proved beyond reasonable doubt the guilt of
Sonny Sabdula y Amanda for
illegal sale of shabu under
Section 5, Article II of R.A. No. 9165, considering the alleged lapses in the handling, marking, inventory, photography, and custodial chain of the seized plastic sachet.
Ruling:
Ratio:
Doctrine: