Case Summary (G.R. No. 186137)
Notice of Appeal and Background
- Datu Not Abdul (appellant) filed a Notice of Appeal on August 4, 2008, contesting the Court of Appeals (CA) Decision dated July 14, 2008.
- The CA affirmed the Regional Trial Court (RTC) Decision dated March 5, 2007, which found the appellant guilty of violating Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
- The primary issue is whether the prosecution adequately established compliance with the chain-of-custody rule.
Prosecution's Case
- On June 25, 2005, Police Officer 2 Daniel E. Akia (PO2 Akia) received a tip about the appellant's illegal drug activities.
- A buy-bust operation was organized, with PO2 Akia posing as a buyer.
- The operation took place in San Vicente, Baguio City, where the appellant was arrested after handing over a sachet of shabu in exchange for buy-bust money.
- The seized item was marked, inventoried, and forwarded to the PNP Regional Crime Laboratory for analysis, confirming it contained methamphetamine hydrochloride.
Defense's Argument
- The appellant pleaded "not guilty" and claimed he was a victim of a frame-up.
- He asserted that he was apprehended without cause and that police officers demanded money for his release.
- The defense presented testimonies from the appellant and his aunt, challenging the credibility of the prosecution's case.
RTC Findings
- The RTC found the testimonies of the prosecution witnesses credible and established the elements of the crime.
- The court ruled that there was a presumption of regularity in the performance of the PDEA officers' duties.
- The appellant was sentenced to life imprisonment and a fine of P500,000.
Appeal to the Court of Appeals
- The appellant appealed, citing inconsistencies in the testimonies of the police officers regarding the buy-bust operation.
- The CA affirmed the RTC's decision, deeming the inconsistencies trivial and finding no merit in the defense's claims of frame-up.
Supreme Court's Ruling
- The Supreme Court recognized significant lapses in the chain of custody of the confiscated sachet, leading to reasonable doubt about the identity of the corpus delicti.
- The Court emphasized that the chain-of-custody rule is crucial in drug cases, requiring strict adherence to ensure the integrity of the evidence.
Chain of Custody Requirements
- The chain-of-custody rule necessitates that every link in the chain of evidence be accounted for, from seizure to presentation in court.
- Key requirements include marking the seized item in the presence of the accused and documenting the transfer of custody at each stage.
Evidentiary Gaps Identified
- The prosecution failed to establish when, where, and how the sachet was marked, leading to questions about its integrity.
- Testimonies from the police officers were inconsistent regarding who had custody of the sachet after its seizure.
- The Joint Affidavit of Arrest indicated discrepancies in the handling of the evidence, undermining the prosecution's case.
Conclusion and Acquittal
- The Supreme Court found that the prosecution did not prove the identity of the seized item beyond a reasonable doubt.
- The CA's ruling was re...continue reading