G.R. No. 180505 ; June 29, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. MARIO MIGUEL Y BERNABE and AMALIA DIZON Y REGACHELO, Defendant-Appellants.

FACTS

Accused-appellants Mario Miguel and Amalia Dizon were charged with violations of Republic Act No. 9165 . Miguel was accused of illegal sale of shabu following a buy-bust operation where he sold a sachet to PO3 Amilassan Salisa, the poseur-buyer. Dizon was charged with illegal possession after a separate sachet was allegedly recovered from her at the same scene. The prosecution’s narrative established that after the sale, the arresting team moved in, and PO1 Janet Sabo apprehended Dizon, from whom a sachet was recovered. The Regional Trial Court found them guilty, a decision affirmed by the Court of Appeals.
The defense presented a starkly different version, claiming they were victims of a frame-up. They testified that they were merely waiting for a ride when police officers, without provocation, arrested them, brought them to a dark area, and demanded money. They asserted that the drugs were planted and that no buy-bust operation occurred. They appealed to the Supreme Court, arguing the prosecution failed to prove their guilt beyond reasonable doubt and failed to establish the integrity of the seized drugs.

ISSUE

The core issue is whether the prosecution successfully proved the guilt of the accused-appellants for the crimes of illegal sale and illegal possession of dangerous drugs beyond reasonable doubt.

RULING

The Supreme Court acquitted both accused-appellants. The ruling hinged on the prosecution’s fatal failure to comply with the chain of custody rule under Section 21 of RA 9165, which is crucial in proving the identity and integrity of the seized drugs—the corpus delicti of the offenses. The Court noted the absence of testimony regarding the immediate marking of the sachet allegedly seized from Dizon. PO1 Sabo testified she gave the sachet to the investigator, but there was no account of who marked it or when. This gap breaks the chain of custody, creating doubt as to whether the item presented in court was the same one recovered from her.
Furthermore, the Court found the police officers’ conduct suspicious and inconsistent with standard buy-bust procedure. The team did not coordinate with the Philippine Drug Enforcement Agency (PDEA) as required. More critically, the poseur-buyer, PO3 Salisa, testified he never actually saw the sachet allegedly taken from Dizon, nor did he witness her arrest, contradicting PO1 Sabo’s account. These material inconsistencies, coupled with the defense’s credible claim of being framed for refusing to pay extortion money, reinforced reasonable doubt. The presumption of regularity in the performance of official duty was overturned by these clear lapses. Consequently, the guilt of the accused-appellants was not established with the required moral certainty, warranting acquittal.