Title
People vs. Sorin y Tagaylo
Case
G.R. No. 212635
Decision Date
Mar 25, 2015
Charlie Sorin acquitted of drug charges due to lapses in chain of custody; seized shabu's integrity compromised by improper marking, raising reasonable doubt.

Case Digest (G.R. No. 212635)
Expanded Legal Reasoning Model

Facts:

  • Charging and Allegations
    • On November 2, 2005, Sorin was charged with violating Sections 5 and 15, Article II of Republic Act No. 9165 (the Comprehensive Dangerous Drugs Act of 2002).
    • The charge centered on the alleged sale of two sachets containing a white crystalline substance (later identified as shabu) for a total of Four Hundred Pesos (PHP400.00) at Amoros, El Salvador, Misamis Oriental.
  • Preceding Investigation and Operational Setup
    • Prior to the alleged transaction, on or about October 25, 2005, the Philippine National Police (PNP) conducted a test-buy operation in which Sorin allegedly sold drugs to a civilian asset.
    • Subsequent to receiving a report regarding Sorin’s alleged sale, PCI Soguillon, the local PNP intelligence section chief, organized a buy-bust team.
      • The team comprised PO2 Edgardo Dador and PO1 Sonny Adams Cambangay as poseur-buyers.
      • Backup personnel included PO3 Edilberto Estrada, SPO1 Graciano Mugot Jr., SPO1 Samuel Madjos, and SPO2 Elias Villarte.
  • The Buy-Bust Operation and Seizure of Evidence
    • At approximately 7:30 p.m. on November 2, 2005, the buy-bust team approached Sorin’s residence in Barangay Amoros.
    • Upon entry into the house, the officers requested to purchase shabu; Sorin stated that each sachet cost PHP200.00.
    • Following the transaction where PO2 Dador exchanged marked money for the two sachets, Sorin was tapped on the shoulder, detained, and later arrested outside his residence.
  • Handling, Testing, and Chain of Custody of the Evidence
    • At the police station, PO2 Dador turned over the seized items and marked money to SPO1 Mugot.
    • SPO1 Mugot confirmed the receipt, prepared the inventory, and requested laboratory examination.
    • The PNP Crime Laboratory tested:
      • The sachets for the presence of illegal drugs, which tested positive for methamphetamine hydrochloride (shabu).
      • Sorin’s hands and the marked money for traces of ultraviolet fluorescent powder.
      • Sorin’s urine for signs of drug use (which tested positive, though later deemed inadmissible).
  • Defense Denials and Allegations of Misconduct
    • Sorin denied that any buy-bust operation had occurred.
    • He asserted that his property was forcibly entered without a warrant and that the shabu was planted by police officers.
    • Sorin maintained that he was at home with his family when the alleged incident occurred.
  • Testimonies and Evidence Presented at Trial
    • The prosecution relied on the straightforward, categorical testimonies of the police officers to establish the conduct of the buy-bust operation.
    • Two defense witnesses, Rhiza Jane A. Lopez and Enriquita De Paira, testified to support Sorin’s version of events, with their accounts highlighting:
      • The destruction of the door of the residence.
      • The sighting of individuals forcibly entering the premises and later leaving with Sorin.
  • Trial Court Proceedings and RTC Ruling
    • On August 3, 2011, the Regional Trial Court (RTC) found Sorin guilty beyond reasonable doubt of violating Section 5, Article II of RA 9165.
    • The RTC sentenced him to Life Imprisonment and imposed a fine of PHP500,000.00.
    • While the seizure and subsequent chain of custody of the sachets were emphasized, the RTC excluded the laboratory results of Sorin’s urine due to issues with the manner of obtaining his consent.
  • Appellate Proceedings
    • Sorin appealed his conviction before the Court of Appeals (CA).
    • On February 27, 2014, the CA affirmed the RTC’s ruling in toto, upholding the conviction and the evidentiary basis of the buy-bust operation.
    • The CA acknowledged certain procedural lapses in the execution of Section 21, Article II of RA 9165 but maintained that the identity and integrity of the seized drugs were preserved.
  • Supreme Court Resolution
    • The Supreme Court reviewed the case on ordinary appeal filed by Sorin.
    • The central focus was the integrity of the chain of custody, particularly whether the marking and identification of the seized sachets were properly maintained.
    • The Court found significant gaps:
      • PO2 Dador failed to mark the seized sachets at the time of apprehension and merely handed them over to SPO1 Mugot.
      • SPO1 Mugot admitted that he did not mark the actual sachets but only the transparent plastic cellophane container in which the sachets were placed.
    • These lapses rendered the evidence highly susceptible to tampering, planting, or contamination.
    • Owing to the unresolved doubts regarding the identity of the corpus delicti, the Court granted the appeal, reversed the previous decisions, and acquitted Sorin.

Issues:

  • Whether the prosecution was able to prove beyond reasonable doubt:
    • The identities of the buyer and the seller involved in the illegal drug transaction.
    • The object (the dangerous drug) and the consideration (payment) exchanged.
    • The complete and uninterrupted delivery of the drug and the corresponding payment.
  • Whether the integrity and evidentiary value of the corpus delicti were preserved through a proper chain of custody.
    • The failure by PO2 Dador to mark the seized sachets at the moment of apprehension.
    • SPO1 Mugot’s practice of marking only the plastic cellophane, not the individual sachets.
  • Whether the identified procedural lapses in handling and marking the seized evidence created sufficient doubt to warrant an acquittal.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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