Title
Supreme Court
People vs. Sali y Alawaddin
Case
G.R. No. 236596
Decision Date
Jan 29, 2020
Mustafa Sali charged under drug laws for selling/possessing shabu; courts initially convicted, but Supreme Court acquitted due to broken custody chain, procedural non-compliance, and reasonable doubt.

Case Digest (G.R. No. 236596)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • Parties Involved
1.1. Plaintiff-Appellee: People of the Philippines 1.2. Accused-Appellant: Mustafa Sali y Alawaddin, also known as "Tapang/Pang"
  • Charges Filed
2.1. Violation of Section 5, Article II of Republic Act (R.A.) No. 9165 (illegal sale of dangerous drugs) 2.2. Violation of Section 11, Article II of R.A. No. 9165 (illegal possession of dangerous drugs)
  • Sequence of Events and Operational Details
    • Pre-Incident Reports and Preparation
1.1. On June 21, 2010, a Confidential Informant (CI) reported that “Tapang” was engaged in selling drugs in Campo Islam, Zamboanga City 1.2. Coordination among law enforcement personnel including Intelligence Officers and a Senior Police Officer initiated a buy-bust operation 1.3. IO1 Michael C. Lanza was designated as the poseur-buyer and assigned a marked money of two hundred pesos (P200.00)
  • Execution of the Buy-Bust Operation
2.1. The operation commenced around 1:00 p.m. when IO1 Lanza and the CI presented themselves at Sali’s sari-sari store 2.2. Sali, who was visible from the store, responded to the call by the CI and proceeded to engage in the transaction 2.3. The transaction involved Sali selling a small sachet containing white crystalline substance in exchange for P200.00 2.4. Immediately following the transaction, the operation signaled its culmination by IO1 Lanza removing his bull cap, which was the prearranged signal for arrest 2.5. IO1 Natividad assisted by arresting Sali at the scene and conducting a subsequent body search that led to the discovery of another sachet, a coin purse, the marked money, and additional paper bills
  • Evidence and Chain of Custody Procedures
    • Presentation and Marking of Evidence
1.1. Two separate sachets were recovered: one weighing 0.0241 gram (sold) and another weighing 0.0155 gram (found upon frisking) 1.2. Both sachets were physically marked by IO1 Sacro, who also handled the evidence throughout the seizure, including a Certificate of Inventory which was later used to establish chain of custody
  • Laboratory Examination
2.1. The sachets were submitted to the Philippine National Police Crime Laboratory in Zamboanga City for qualitative analysis 2.2. Chemistry Report No. D-031-2010 confirmed the presence of Methamphetamine Hydrochloride (shabu) in both samples 2.3. A subsequent urine test on Sali also yielded a positive result for Methamphetamine Hydrochloride
  • Defense Version and Argument
    • Alibi and Circumstantial Details
1.1. Sali contended that between 12:00 and 1:00 p.m. of June 21, 2010, he was at his parents’ house assisting with a family celebration 1.2. He described being coerced and taken by armed individuals, which led to his arrest, thereby suggesting irregularities in the procedure
  • Claims Regarding Procedural Irregularities
2.1. Sali argued that the physical inventory and photographic documentation of the seized drugs were not conducted at the scene of the buy-bust operation 2.2. He contested the uniqueness and reliability of the markings on the seized sachets, which were limited to mere initials without a proper signature or date as required by law 2.3. The defense underscored that his constitutional rights were compromised during the arrest process
  • Trial Court and Appellate Court Decisions
    • Regional Trial Court (RTC) Decision (March 31, 2014)
1.1. Sali was found guilty beyond reasonable doubt for both charges 1.2. Sentences imposed were: 1.2.1. Life imprisonment and a fine of P500,000.00 for illegal sale of dangerous drugs 1.2.2. Imprisonment ranging from 12 years and 1 day to 20 years, alongside a fine of P300,000.00 for illegal possession of dangerous drugs
  • Court of Appeals (CA) Decision (November 21, 2017)
2.1. The CA affirmed the RTC’s decision 2.2. The CA held that the prosecution evidence established an unbroken chain of custody despite minor deviations from procedural requirements

Issues:

  • Chain of Custody of the Seized Evidence
    • Whether the chain of custody of the seized sachets of shabu was properly maintained from seizure to presentation in court
    • Whether the physical inventory and photographic requirements under Section 21 of R.A. No. 9165 and its IRR were complied with at the scene of the buy-bust operation
  • Sufficiency and Integrity of the Evidence
    • Whether the prosecution established beyond reasonable doubt that the tiny quantities (0.0241 gram and 0.0155 gram) recovered were the identical substances offered as evidence
    • Whether the mere presence of initials (without a full signature or proper dating) on the evidence sufficed to confirm its authenticity and integrity
  • Procedural Irregularities and the Defendant’s Rights
    • Whether the deviation from the mandated inventory procedures (conducting the physical inventory and photographing the evidence away from the crime scene) can be justified on security grounds
    • Whether the absence of the defendant’s (or his representative’s) presence during the inventory process constitutes a violation affecting the evidentiary chain

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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