G.R. No. 233470 - People vs. Banding y Ulama

Case Summary (G.R. No. 233470)

Applicable Law

The relevant legislation in this matter is Republic Act No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002, particularly Article II, Section 5, which pertains to illegal sale of dangerous drugs.

Background of the Case

On September 20, 2010, the police, aided by a confidential informant, executed a buy-bust operation against Banding, who was accused of selling methamphetamine hydrochloride, commonly known as "shabu." The transaction led to his arrest, and he was later charged with violating the aforementioned law. Banding pleaded not guilty, and the trial commenced with both sides presenting their evidence.

Prosecution's Evidence

The prosecution presented a series of witnesses, including police officers directly involved in the buy-bust operation. These testimonies outlined the sequence of events leading up to Banding's arrest, pointing to his selling of a sachet containing an illegal drug. The prosecution emphasized the procedural adherence involving the seizure and inventory of the drug.

Defense's Argument

Banding's defense centered on an alibi that he was kidnapped by armed individuals who forced him to cooperate with the police. He maintained that the police officers planted the evidence against him and highlighted significant inconsistencies in the handling of the seized items.

Trial Court Findings

The Regional Trial Court found Banding guilty beyond reasonable doubt of selling illegal drugs and sentenced him to life imprisonment plus a fine, ruling that the buy-bust operation was valid and maintained that the integrity of the evidence was preserved.

Court of Appeals Decision

On appeal, the Court of Appeals upheld the trial court's decision but made modifications regarding the penalty. The appellate court recognized the presumption of regularity in the conduct of the police officers and ruled that any minor errors did not warrant the accused’s acquittal.

Issues on Appeal

Banding’s appeal raised questions about the chain of custody of the confiscated drugs, arguing that the police did not conduct the inventory in a practical location and lacked proper witnesses during the procedures. Banding pointed out that the discrepancies in the inventory receipt and laboratory report undermined the prosecution’s evidence.

Chain of Custody Standards

As established in various jurisprudence and under Section 21 of RA 9165, strict compliance with chain of custody requirements is crucial for maintaining the integrity and admissibility of evidence in drug-related cases. The prosecution carries the burden to show a continuous unbroken chain from seizure to presentation in court.

Court's Resolution

The Supreme Court found mer