GR 242686; (July, 2020) (Digest)
G.R. No. 242686 , July 07, 2020
People of the Philippines, Plaintiff-Appellee, vs. Zaldy Sioson y Limon, Accused-Appellant.
FACTS
The accused-appellant, Zaldy Sioson y Limon, was charged with illegal sale and illegal possession of dangerous drugs under Sections 5 and 11, Article II of Republic Act No. 9165 . The prosecution alleged that on October 27, 2015, a buy-bust operation was conducted in Barangay Sta. Rosa, Pilar, Bataan. PO1 Juncarl G. Pataweg, as the poseur-buyer, bought one plastic sachet of shabu from Sioson for a marked P500 bill. Upon arrest, four additional plastic sachets were recovered from Sioson’s pockets. The seized items were marked at the place of arrest in the presence of Sioson only. The inventory and photography were later conducted at the police station in the presence of a media representative, a DOJ representative, and a barangay official. The items tested positive for methamphetamine hydrochloride. Sioson denied the charges, claiming he was at a wake in Pampanga when he was allegedly abducted and assaulted by police officers.
ISSUE
Whether the prosecution established the guilt of the accused-appellant beyond reasonable doubt by complying with the chain of custody requirements under Section 21, Article II of R.A. No. 9165 , as amended.
RULING
No. The Supreme Court reversed the decisions of the lower courts and acquitted the accused-appellant. The Court found that the apprehending officers committed a serious breach of the mandatory chain of custody procedures. Specifically, the required witnesses (an elected public official, a representative from the National Prosecution Service or the media) were not present during the seizure and marking of the drugs at the place of arrest. Furthermore, the inventory and photography were not conducted immediately at the place of seizure but only at the police station. The prosecution failed to acknowledge or justify these deviations from the prescribed procedure. The unjustified non-compliance with the chain of custody rule cast reasonable doubt on the integrity and evidentiary value of the seized drugs, which is essential to prove the corpus delicti of the crimes. Consequently, the accused-appellant is acquitted.