GR 179936; (April, 2012) (Digest)
G.R. No. 179936; April 11, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JAMAD ABEDIN y JANDAL, Accused-Appellant.
FACTS
Accused-appellant Jamad Abedin was charged with illegal sale and possession of dangerous drugs. The prosecution evidence established that a buy-bust operation was conducted on May 10, 2005, in Pasig City. PO1 Anthony Bibit, acting as poseur-buyer, purchased a plastic sachet of shabu from Abedin using marked money. Upon arrest, another sachet was recovered from Abedin’s pocket. The seized items were marked and later confirmed by forensic examination to be methamphetamine hydrochloride.
The defense presented a different narrative, alleging that Abedin was arbitrarily arrested on May 9, 2005, while waiting for a tricycle to bring his daughter-in-law to the hospital. He claimed the arresting officers demanded money for his release. The Regional Trial Court convicted Abedin, a decision affirmed by the Court of Appeals. He appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt and alleging non-compliance with the chain of custody requirements under Section 21 of Republic Act No. 9165.
ISSUE
The core issue is whether the prosecution successfully established the identity and integrity of the seized dangerous drugs, constituting the corpus delicti of the crimes, despite alleged lapses in the chain of custody procedure.
RULING
The Supreme Court affirmed the conviction. The Court held that while the arresting team did not strictly comply with the witness requirements of Section 21 of R.A. 9165—specifically the presence of a representative from the media, the Department of Justice, and an elected public official during the inventory—such procedural lapse did not automatically invalidate the seizure or render the evidence inadmissible. The law allows for justifiable grounds for non-compliance. Here, the prosecution successfully established through the testimonies of the police officers the crucial links in the chain of custody: the immediate marking of the seized sachets at the place of arrest, their transfer to the investigating officer, submission to the crime laboratory, and eventual presentation in court. The integrity and evidentiary value of the seized items were preserved. The defense of frame-up was rejected for being unsubstantiated and inherently weak. The positive identification by the police officers, who are presumed to have performed their duties regularly, prevailed over the accused’s bare denial.