G.R. No. 243941 , March 11, 2020
People of the Philippines, Plaintiff-Appellee v. Samiah S. Abdulah, Accused-Appellant

FACTS

Accused-appellant Samiah S. Abdulah and a minor (EB) were charged with violating Section 5 of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act) for the illegal sale of dangerous drugs. The prosecution alleged that on November 21, 2014, in Marikina City, a buy-bust operation was conducted where PO3 Erich Joel Temporal, acting as poseur-buyer, purchased a plastic sachet of shabu from Abdulah and EB using marked money. Upon consummation of the sale, the accused were apprehended. The buy-bust team, believing the area was unsafe for being “a Muslim area,” brought the accused to the barangay hall where they conducted the inventory and photographing of the seized items in the presence of a barangay tanod and a barangay kagawad, the accused, but without representatives from the media or the National Prosecution Service. The seized items tested positive for methamphetamine hydrochloride. The Regional Trial Court convicted Abdulah, sentencing her to life imprisonment and a fine. The Court of Appeals affirmed the conviction. Abdulah appealed, arguing non-compliance with the chain of custody requirements under Section 21 of RA 9165.

ISSUE

Whether the Court of Appeals correctly upheld the conviction of accused-appellant Samiah S. Abdulah for illegal sale of dangerous drugs despite alleged deviations from the chain of custody requirements under Section 21 of RA 9165.

RULING

No. The Supreme Court reversed the Court of Appeals Decision and acquitted accused-appellant Samiah S. Abdulah. The Court held that the prosecution failed to establish an unbroken chain of custody and to prove justifiable grounds for the procedural lapses. The apprehending officers did not strictly comply with Section 21 of RA 9165, as amended. The inventory and photographing were not conducted immediately at the place of seizure but at the barangay hall, and were not witnessed by the required insulating witnesses—a representative from the media and the National Prosecution Service, or an elected public official. The officers’ mere averment that the place of arrest was a “Muslim area” and thus unsafe was deemed a cursory and shallow justification, insufficient to excuse non-compliance. The prosecution did not demonstrate that the officers took concrete steps to ensure the integrity and evidentiary value of the seized items despite the deviation. Consequently, the integrity and identity of the corpus delicti were compromised, and the prosecution failed to prove Abdulah’s guilt beyond reasonable doubt.