G.R. No. 162064 March 14, 2006
Sonny Zarraga vs. People of the Philippines

FACTS

The prosecution’s evidence established that a buy-bust operation was conducted against petitioner Sonny Zarraga and his co-accused. A police team, with a designated poseur-buyer, arranged a purchase of 100 grams of shabu at a restaurant in Calamba, Laguna. Zarraga arrived, negotiated the sale, and directed his companion to hand over the drugs. Upon consummation of the sale and the pre-arranged signal, the team arrested Zarraga and recovered the marked money. Forensic examination confirmed the substance was methamphetamine hydrochloride.
The defense presented a starkly different version, alleging that Zarraga and his companion were victims of a kidnapping and extortion scheme by police officers a day before the alleged buy-bust. They claimed they were abducted in Metro Manila, robbed, and later framed by planting evidence. They were only brought to Laguna the following day after ransom negotiations with Zarraga’s wife failed.

ISSUE

The core issue is whether the prosecution proved Zarraga’s guilt for the illegal sale of dangerous drugs beyond reasonable doubt, amidst the conflicting claims of a legitimate buy-bust operation versus a frame-up.

RULING

The Supreme Court acquitted Zarraga. The ruling hinged on the prosecution’s failure to establish an unbroken chain of custody over the seized drugs, a critical requirement in drug cases to prevent tampering, substitution, or contamination. The Court noted the police violated the prescribed procedure under Dangerous Drugs Board Regulation No. 2, Series of 1990. The regulation mandates that the seized items be physically inventoried and photographed immediately after seizure in the presence of the accused or his representative, who shall sign the inventory.
The record was devoid of any evidence that this required inventory was conducted at the place of arrest or at any time in Zarraga’s presence. The prosecution witnesses did not testify to creating such an inventory or obtaining Zarraga’s signature thereon. This lapse created reasonable doubt about the integrity and identity of the evidence presented in court. The defense’s claim of frame-up, while not proven, gained plausibility due to this procedural breach. Consequently, the presumption of regularity in the performance of official duty was overturned. Without the essential proof of an unbroken chain of custody, Zarraga’s guilt could not be sustained beyond reasonable doubt.