G.R. No. 186141 ; April 11, 2012
People of the Philippines, Plaintiff-Appellee, vs. Jesusa Figueroa y Coronado, Accused-Appellant.

FACTS

Accused-appellant Jesusa Figueroa was charged with illegal possession and attempted sale of shabu under Republic Act No. 9165 . The prosecution’s narrative established that a buy-bust operation was set after an informant reported Figueroa’s drug activities. PO3 Josefino Callora was designated as the poseur-buyer. On July 2, 2004, at the agreed location, Figueroa arrived in a vehicle, showed a plastic sachet from a Chowking bag, and asked for the money. Before the exchange, she sensed police presence and sped away. A chase ensued, and her vehicle was intercepted. A companion was seen throwing the Chowking bag onto the pavement, from which a sachet of shabu was recovered. Additional sachets were later found under the floor mat of Figueroa’s vehicle during an inventory.
The defense presented a starkly different version, claiming Figueroa was merely giving a ride to friends and was forcibly taken by armed men who planted the evidence. She denied any agreement to sell drugs or any knowledge of the substances found. The Regional Trial Court convicted her for both charges, which the Court of Appeals affirmed. Figueroa appealed to the Supreme Court, arguing the prosecution failed to prove her guilt beyond reasonable doubt and that the apprehending officers lacked authority under RA 9165.

ISSUE

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

RULING

The Supreme Court acquitted Figueroa. The legal logic centered on the failure of the prosecution to establish the identity and integrity of the seized drugs, which is crucial in drug cases. The Court found a broken chain of custody. The sachet allegedly shown during the attempted sale was not the same one presented in court; the evidence presented was the sachet recovered from the pavement after the chase. There was no testimony directly linking this exhibited sachet to the one Figueroa purportedly showed. Furthermore, the prosecution did not adequately account for the handling of the evidence from the time it was picked up at the scene until its presentation in court, creating doubt about its authenticity. Regarding the charge of attempted sale, the Court ruled that the overt act of showing the drugs and asking for payment constituted mere preparation, not a direct attempt to commence the sale, as there was no actual delivery or payment. The elements of an attempted felony under the Revised Penal Code were not satisfied. The Court also noted the defense of frame-up was weak but emphasized that the burden of proof lies with the prosecution, which it failed to discharge. Consequently, the presumption of innocence prevailed.