Case Digest (G.R. No. 262732)
Facts:
On March 31, 2018 at Robinsons Mall parking lot, Mongcao Basaula Sabino a.k.a. "Salik" and Saima Diambangan Mipandong were arrested in a PDEA buy-bust after an informant delivered a gray pouch containing four knotted plastic bags of white crystalline substance; the items were marked at the scene, inventoried at PDEA headquarters, and tested positive for methamphetamine hydrochloride by Chemist Anna Loe Montilla. The Regional Trial Court convicted both accused of illegal sale of dangerous drugs under Section 5, R.A. No. 9165; the Court of Appeals affirmed, and the accused appealed to the Supreme Court.
Issues:
- Did the prosecution prove beyond reasonable doubt that Sabino and Mipandong committed illegal sale of dangerous drugs under Section 5, R.A. No. 9165?
- Did noncompliance with Section 21, R.A. No. 9165, as amended by R.A. No. 10640, invalidate the chain of custody and require acquittal?
Ruling:
The Appeal was denied and the Court of Appeals Decision was affirmed with modification. Sabino and Mipandong were found guilty beyond reasonable doubt of illegal sale of dangerous drugs and sentenced to life imprisonment and a fine of PHP 500,000.00 each, with the phrase "without eligibility for parole" deleted.
Ratio:
The Court held that the prosecution proved an unbroken chain of custody and preserved the integrity and evidentiary value of the seized drugs despite procedural deviations. Applying the saving mechanism in Section 21 as amended, the Court found justifiable grounds for conducting the inventory at PDEA headquarters given safety risks at a crowded mall and that marking, immediate custody by Agent Anonas, inventory with insulating witnesses, turnover to the forensic chemist, and in-court identifications satisfied the two requisites articulated in People v. Taglucop: justifiable grounds for noncompliance and preservation of evidentiary integrity.
Doctrine:
- The illicit drug seized in illegal sale cases constitutes the *corpus delicti* and its existence must be proven beyond reasonable doubt.
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