GR 184758; (April, 2014) (Digest)
G.R. No. 184758 , April 21, 2014.
PEOPLE OF THE PHILIPPINES, Appellee, vs. SONNY SABDULA y AMANDA, Appellant.
FACTS
Appellant Sonny Sabdula y Amanda was charged with violating Section 5, Article II of R.A. No. 9165 (illegal sale of dangerous drugs) for allegedly selling 0.10 gram of shabu in Quezon City on February 1, 2004. The prosecution’s evidence, primarily through PO2 Bernard Centeno, established that a buy-bust operation was conducted based on a tip. PO2 Centeno acted as poseur-buyer, purchased the shabu from the appellant for ₱200.00, and effected the arrest. The seized plastic sachet was forwarded to the crime laboratory, where it tested positive for methylamphetamine hydrochloride. The defense presented an alibi, with the appellant testifying that he was forcibly taken from a taxi in Taguig City on January 29, 2004, and brought to the police station where he was falsely charged after a ransom demand was made on his sister. The Regional Trial Court convicted the appellant and sentenced him to life imprisonment and a fine, a decision affirmed by the Court of Appeals.
ISSUE
Whether the prosecution proved the appellant’s guilt beyond reasonable doubt for the illegal sale of shabu, particularly with respect to establishing the identity and integrity of the corpus delicti through an unbroken chain of custody.
RULING
The Supreme Court ACQUITTED the appellant. The prosecution failed to prove his guilt beyond reasonable doubt due to a broken chain of custody over the seized drugs. The Court emphasized that in drug cases, the identity and integrity of the corpus delicti must be preserved with moral certainty. Crucial to this is the immediate marking of the seized item upon confiscation, which serves as the starting point of the custodial link and prevents switching, planting, or contamination. The records, including the testimony of PO2 Centeno and the stipulated testimonies of other officers, did not show that the seized plastic sachet was ever marked at the time of seizure, at the police station, or at any point. This procedural lapse created serious uncertainty about whether the item presented in court was the same one seized from the appellant, thereby breaking the chain of custody. The presumption of regularity in the performance of official duty cannot prevail over the constitutional presumption of innocence and the prosecution’s failure to establish an essential element of the crime. The appellant was ordered immediately released unless detained for another lawful cause.