Facts:
Alsarif Bintaib y Florencio, also known as “Leng,” was charged with the illegal sale of shabu in violation of Section 5, R.A. No. 9165, following his arrest on November 11, 2008, in Zamboanga City. Acting on information received from a confidential asset about Bintaib’s drug activities, the Philippine Drug Enforcement Agency-9 organized a buy-bust operation. Intelligence Officer 2 Abdulsokor Abdulgani acted as the poseur-buyer, while Officer Maria Niña Belo served as backup. Bintaib delivered a heat-sealed plastic sachet of shabu to Abdulgani, who then signaled for the arrest.
At trial, Bintaib contested the validity of the buy-bust operation and the handling of the seized drugs, alleging non-compliance with procedural safeguards under R.A. No. 9165. The Regional Trial Court convicted Bintaib, which was affirmed by the Court of Appeals (CA). Bintaib then appealed to the Supreme Court.
Issues:
1. Whether the buy-bust operation and the subsequent handling of the seized shabu complied with the requirements set forth under R.A. No. 9165.
2. Whether the chain of custody of the seized shabu was properly preserved to ensure its integrity and evidentiary value.
Court’s Decision:
The Supreme Court acquitted Bintaib, finding merit in his appeal. The Court ruled that the prosecution failed to prove beyond reasonable doubt Bintaib’s guilt due to non-compliance with the procedural requirements under Section 21 of R.A. No. 9165. The Court highlighted the importance of strict adherence to the prescribed chain of custody procedure to ensure the integrity of the seized drugs. It was noted that the mandatory presence of the insulating witnesses during marking and inventory was not adhered to and that the prosecution did not present a justifiable reason for such non-compliance.
Doctrine:
The case reiterates the doctrine on the importance of complying with the prescribed chain of custody procedure under Section 21 of R.A. No. 9165. The integrity and evidentiary value of seized drugs are paramount, and failure to strictly follow the procedural requirements necessitates acquittal due to reasonable doubt regarding the drugs’ authenticity.
Class Notes:
– Chain of Custody in Drug Cases: Requires immediate marking and inventory of seized drugs in the presence of the accused, a representative from the media, the Department of Justice, and an elected public official to ensure integrity and evidentiary value. (Section 21, R.A. No. 9165)
– Non-compliance with Chain of Custody: Automatic acquittal unless the prosecution can show justifiable reasons for deviation and ensure the integrity of the seized drugs.
Historical Background:
R.A. No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002, places stringent requirements on handling and custody of seized drugs to protect against tampering and to preserve their evidentiary value. The law reflects the government’s effort to tackle drug-related crimes while ensuring the rights of individuals are protected against possible abuse by law enforcers. This case underscores the judiciary’s role in maintaining the balance between efficient law enforcement and safeguarding individual rights.
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