**Facts:**
1. **Incident and Charges:** On January 2, 2003, Roldan Morales was accused of illegal possession (0.03g) and sale of methylamphetamine hydrochloride (shabu). Two separate informations were filed against him in Quezon City.
– **Criminal Case No. Q-03-114256:** Possession of 0.03 grams of shabu.
– **Criminal Case No. Q-03-114257:** Sale of 0.03 grams of shabu.
2. **Arraignment and Joint Trial:** Morales pleaded not guilty to both charges in Filipino. On the prosecutor’s motion, the cases were consolidated for a joint trial.
3. **Buy-Bust Operation:**
– **Preparation:** PO1 Roy prepared a pre-operation report and proceeded to Brgy. San Vicente with PO3 Rivera and an informant. PO3 Rivera prepared marked money and recorded their serial numbers.
– **Transaction:** The operation took place at the parking lot of Jollibee Philcoa. During the deal, Morales handed a sachet of shabu to PO1 Roy for P100.00. PO1 Roy’s pre-arranged signal led to Morales’ arrest by PO3 Rivera, who found additional paraphernalia.
– **Forensic Examination:** The seized items tested positive for shabu at the crime laboratory.
4. **Defense:** Morales denied the allegations, claiming he was a parking attendant and had been framed by officers. Witnesses, including his employer and mother, corroborated his defense.
**Procedural Posture:**
1. **RTC Decision:** The RTC found Morales guilty in both cases and sentenced him to life imprisonment for the sale and a term for possession. It emphasized the positive identification of Morales and the physical evidence (sachets of shabu).
2. **Appeal to CA:** The CA affirmed the RTC’s decision in toto, rejecting Morales’ claims of instigation and doubting issues surrounding the seized items’ identity and chain of custody.
3. **Supreme Court Appeal:** Morales filed a Notice of Appeal to the Supreme Court. The Supreme Court accepted the case and the parties submitted their briefs.
**Issues:**
1. **Whether there was proof beyond a reasonable doubt for the illegal sale and possession of shabu.**
2. **Whether procedural lapses in the handling of evidence, particularly under Section 21 of RA 9165, warranted an acquittal.**
**Court’s Decision:**
1. **Proof of Illegal Sale and Possession:**
– The Supreme Court emphasized the necessity of proving the identity of the corpus delicti beyond a reasonable doubt. It highlighted the mandatory nature of procedures set by RA 9165, which involve the immediate marking, inventory, and photographing of seized items in the presence of the accused and other witnesses.
2. **Procedural Lapses:**
– The arresting officers admitted not marking the seized items immediately and not observing other requisite procedures such as having a representative from the media, DOJ, or elected official. This deviation from standard procedures created a reasonable doubt about the integrity and identity of the seized drugs.
– The testimonies revealed inconsistencies and inadequacies in the chain of custody and handling of evidence.
**Doctrine:**
– **Strict Adherence to Section 21 RA 9165:** The case reiterated the critical importance of adhering to the procedures mandated in Section 21 of RA 9165 for the custody and disposition of confiscated drugs. Non-compliance, without justifiable grounds, casts doubt on the identity of the corpus delicti, potentially leading to acquittal.
– **Chain of Custody:** The identity of the corpus delicti must be proven through an unbroken chain of custody. Flaws or breaks in this chain can be fatal to the prosecution’s case.
**Class Notes:**
1. **Elements of Illegal Sale of Dangerous Drugs:** Proof of transaction and presentation of corpus delicti.
2. **Elements of Illegal Possession of Dangerous Drugs:** Proof of possession, lack of legal authorization, and awareness of possession.
3. **Section 21, RA 9165:** Requires the marking, inventory, and photographing of seized drugs in the presence of the accused and specific witnesses.
– **Section 21(a) IRR:** Non-compliance is excusable only if it does not compromise the integrity and evidentiary value of the seized items and is justified.
**Historical Background:**
The case highlights the judicial system’s evolving approach to anti-drug operations in the Philippines, particularly the rigorous evidence handling procedures mandated by RA 9165. This strict adherence reflects broader efforts to enforce more transparent and reliable law enforcement actions amid concerns of wrongful convictions and evidence tampering.
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