G.R. No. 242160 . July 8, 2019.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JAN JAN TAYAN y BALVIRAN and AIZA SAMPA y OMAR, Accused; AIZA SAMPA y OMAR, Accused-Appellant.

FACTS

An Information charged Jan Jan Tayan and Aiza Sampa with violating Section 5, Article II of R.A. No. 9165 (illegal sale of dangerous drugs). The prosecution’s version states that on February 24, 2014, a buy-bust operation was conducted in Quezon City. A confidential informant facilitated a deal with Tayan (“Mike”). PDEA IO1 Jonis Asaytono acted as poseur-buyer. Tayan, after being shown the buy-bust money, called Sampa, who arrived and handed a plastic sachet of white substance to Tayan. Tayan then gave the sachet to IO1 Asaytono in a comfort room in exchange for the money. Upon the pre-arranged signal, arrests were made. A commotion occurred, prompting the team to leave immediately. The marking of the seized sachet with “JBA EXHA 2/24/14” was done inside the service vehicle. Inventory and photographing were conducted later at Camp Vicente Lim, Laguna, in the presence of the accused and a media representative, but without a DOJ representative or an elected public official. The substance tested positive for methamphetamine hydrochloride. The defense claimed Sampa was arbitrarily arrested while at a Jollibee with her daughter. The RTC and the CA convicted both accused. Sampa appealed to the Supreme Court.

ISSUE

Whether the prosecution established the guilt of accused-appellant Aiza Sampa beyond reasonable doubt for illegal sale of dangerous drugs, particularly in light of compliance with the chain of custody requirements under Section 21 of R.A. No. 9165 .

RULING

The Supreme Court ACQUITTED accused-appellant Aiza Sampa. The prosecution failed to prove her guilt beyond reasonable doubt due to substantial gaps in the chain of custody. The apprehending team committed procedural breaches under Section 21 of R.A. No. 9165 . The marking of the seized item was not done immediately at the place of seizure but inside the service vehicle, and the required witnesses (a DOJ representative and an elected public official) were not present during the inventory and photographing at the police station. The prosecution’s justification for these lapses—the existence of a commotion—was not established as a fact and remained uncorroborated. The prosecution also failed to acknowledge the absence of the insulating witnesses and to provide any credible explanation for the deviation from the mandated procedures. These breaches created serious doubt as to the integrity of the seized drug, breaking the chain of custody at its inception. Therefore, the appeal was granted, the CA Decision reversed, and Sampa was ordered immediately released.