GR 192432; (June, 2014) (Digest)
G.R. No. 192432, June 23, 2014
People of the Philippines, Plaintiff-Appellee, vs. Larry Mendoza y Estrada, Accused-Appellant.
FACTS
Accused-appellant Larry Mendoza y Estrada was charged with violations of Sections 5 (illegal sale) and 11 (illegal possession) of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). The prosecution’s evidence, based on a buy-bust operation on August 28, 2007, in Binangonan, Rizal, alleged that PO1 Arnel D. Diocena, acting as poseur-buyer, bought two plastic sachets of shabu from the accused for Php 500.00. Upon arrest, another sachet was allegedly recovered from the accused after a frisk. The seized items were marked “LEM-1,” “LEM-2,” and “LEM-3” and tested positive for methylamphetamine hydrochloride. The defense presented a different version, claiming the accused was framed; that he was arrested at his home after a friend sought his help with police, and that the police demanded protection money.
ISSUE
Whether the Court of Appeals erred in finding the accused guilty beyond reasonable doubt of violations of Sections 5 and 11 of RA No. 9165.
RULING
The Supreme Court REVERSED the decision of the Court of Appeals and ACQUITTED Larry Mendoza y Estrada on the ground of reasonable doubt. The Court held that the prosecution failed to establish an unbroken chain of custody of the seized dangerous drugs, which is crucial to proving the corpus delicti. The buy-bust team committed substantial lapses in complying with the procedure under Section 21 of RA No. 9165. Specifically, the prosecution did not offer any justifiable reason for the absence of the required witnesses (a representative from the media, the Department of Justice, and any elected public official) during the physical inventory and photographing of the seized items. Furthermore, the prosecution failed to present the police officer who actually received and handled the evidence from the arresting officers to the crime laboratory, creating a significant gap in the chain. These lapses negated the presumption of regularity in the performance of official duties by the police officers and compromised the integrity and evidentiary value of the seized drugs. Consequently, the guilt of the accused was not proven beyond reasonable doubt.