Case Summary (G.R. No. 236596)
Factual Background
Mustafa Sali was charged on July 5, 2010, with violating Sections 5 and 11, Article II of R.A. No. 9165, for the sale and possession of methamphetamine hydrochloride, commonly known as shabu. On June 21, 2010, he was apprehended by members of the Philippine Drug Enforcement Agency (PDEA) during a buy-bust operation. A confidential informant had reported his drug-selling activities, leading to a plan to execute the operation where Sali was identified as the seller.
Prosecution's Evidence
During the operation, Sali sold one heat-sealed plastic sachet containing methamphetamine to PDEA agent Michael C. Lanza, who acted as a poseur-buyer. Following the transaction, agents arrested Sali after Lanza signaled, and further searches yielded additional drugs, money, and other items. The prosecution produced three witnesses to establish the events and the drug's presence, including documentation and laboratory results confirming the substance's identity as shabu.
Defense's Claims
Sali, in his defense, argued that he was at a family event during the time of his arrest and did not engage in drug activities. He claimed that he was forcibly taken by armed individuals who lacked proper identification. He also alleged police extortion attempts during interrogation and denied the validity of the evidence presented against him.
RTC Ruling
The RTC found Sali guilty of both charges, sentencing him to life imprisonment for the sale of shabu and a 12 to 20-year term for possession, along with fines. The RTC asserted that the prosecution had established a clear chain of custody for the seized drugs.
CA Ruling
On appeal, the CA affirmed the RTC's decision, emphasizing that the chain of custody remained intact and that the elements of illegal possession were convincingly demonstrated. Sali's arguments regarding the inadequacy of the evidence were dismissed, and the court held that the markings and procedural compliance were sufficient under the law.
Supreme Court's Ruling
The Supreme Court found the appeal meritorious and reversed the previous convictions. It emphasized that for a conviction on illegal drug sales, the prosecution must prove the identity of both the buyer and seller, the object of the sale, and the delivery of the drug, all beyond reasonable doubt. The court determined that the prosecution failed to establish a credible chain of custody for the sachets of shabu.
Chain of Custody Analysis
The court clarified the legal requirements for maintaining a chain of custody as outlined in R.A. No. 9165 and its regulations. It noted that the physical inventory and documentati
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Case Citation
- G.R. No. 236596, January 29, 2020
- 869 Phil. 807
Parties Involved
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellant: Mustafa Sali y Alawaddin a.k.a. "Tapang/Pang"
Background of the Case
- The case revolves around the appeal from the November 21, 2017 Decision of the Court of Appeals (CA) in CA-G.R. CR-HC No. 01335-MIN.
- The CA affirmed the March 31, 2014 Decision of the Regional Trial Court (RTC), 9th Judicial Region, Branch 13, Zamboanga City.
- Mustafa Sali was found guilty beyond reasonable doubt of violating Sections 5 and 11, Article II of Republic Act No. 9165, or the Comprehensive Dangerous Drugs Act of 2002.
Charges Against the Accused
Criminal Case No. 24967 (Sale of Dangerous Drugs):
- Date of the offense: June 21, 2010.
- Allegation: Selling one (1) small heat-sealed transparent plastic sachet containing methamphetamine hydrochloride (shabu) to a poseur-buyer from the Philippine Drug Enforcement Agency (PDEA).
Criminal Case No. 24968 (Illegal Possession of Dangerous Drugs):
- Date of the offense: June 21, 2010.
- Allegation: Possessing one (1) small heat-sealed transparent plastic sachet of methamphetamine hydrochloride (shabu) without lawful authority.
Trial and Proceedings
- Mustafa Sali pleaded not guilty during his arraignment and was detained during the trial.
- The prosecution presented three witnesses: IO1 Michael C. Lanza, IO1 Bracio B. Natividad, and IO1 Joel Sacro.
- The defense presented Mustafa Sali and a witness named Sandra Ahil.