Facts:

• Carlito Valencia y Candelaria was charged with illegal possession of methamphetamine hydrochloride (shabu) under R.A. No. 9165.
• The incident took place on April 8, 2006, in Barangay 18, Caloocan City.
• Police Superintendent Napoleon L. Cuaton conducted a surveillance and buy-bust operation due to reports of illegal drug activities.
• During the operation, PO3 Ferdinand Modina witnessed Valencia placing a plastic sachet containing a white crystalline substance as a bet in a game of cara y cruz.
• Modina seized the sachet and arrested Valencia, who subsequently produced another sachet from his pocket.
• The seized items were marked and sent to the PNP Crime Laboratory, which confirmed the substances as methamphetamine hydrochloride.
• Valencia denied the charges, alleging wrongful arrest and police extortion for his release.
• The Regional Trial Court (RTC) found him guilty, resulting in imprisonment and a fine.
• Valencia appealed, claiming the prosecution failed to establish an unbroken chain of custody for the seized drugs, but the Court of Appeals (CA) upheld the RTC's decision.

Issue:

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Ruling:

• The Supreme Court ruled in favor of Valencia, reversing the decisions of both the RTC and CA.
• Valencia was acquitted due to the prosecution's inability to prove guilt beyond a reasonable doubt, primarily due to significant lapses in the chain of custody of ...(Unlock)

Ratio:

• The Supreme Court highlighted the importance of a clear chain of custody in drug possession cases to ensure the identity and integrity of the seized drugs.
• The prosecution failed to demonstrate that the sachets were marked in Valencia's presence, which is a crucial procedural requirement.
• There was ambiguity regarding who handled the sachets from the time of seizure to laboratory examinat...continue reading