### Facts:
This case initiated from two separate informations filed on September 15, 2004, against Garry dela Cruz y De Guzman, accusing him of illegal sale and illegal possession of dangerous drugs, specifically Methamphetamine Hydrochloride (shabu), in violation of Sections 5 and 11 of Republic Act No. 9165, otherwise known as the Comprehensive Dangerous Drugs Act of 2002. Following a tip from a civilian informant about the illegal drug activities of a certain “Gary” in Zamboanga City, a buy-bust operation was orchestrated by the Zamboanga City Police Office. PO1 Wilfredo Bobon acted as the buyer with SPO1 Roberto Roca as backup. During the operation, dela Cruz allegedly sold a sachet of shabu to Bobon in exchange for marked money, after which six more sachets were found in his possession upon arrest.
The procedural path to the Supreme Court involved dela Cruz’s conviction by the Regional Trial Court, Branch 13, Zamboanga City on August 19, 2010, resulting in a life sentence and a fine for the illegal sale of drugs, and 12 to 14 years imprisonment along with a fine for illegal possession. Dela Cruz appealed to the Court of Appeals, which affirmed the lower court’s decision on May 31, 2012. Following his notice of appeal, the case was eventually forwarded to the Supreme Court.
### Issues:
1. Whether the guilt of dela Cruz for violating Sections 5 and 11 of the Comprehensive Dangerous Drugs Act of 2002 was proven beyond reasonable doubt.
2. Whether the prosecution established compliance with the chain of custody requirements under Section 21 of the Comprehensive Dangerous Drugs Act of 2002.
### Court’s Decision:
The Supreme Court reversed the Court of Appeals’ decision, acquitting Garry dela Cruz. The Court scrutinized the chain of custody procedure and highlighted the prosecution’s failure to definitively preserve the integrity and evidentiary value of the seized drugs. The Supreme Court noted critical lapses in the handling of the confiscated items, particularly the absence of a proper physical inventory and photography of the seized drugs in the presence of the required witnesses as mandated by Section 21 of Republic Act No. 9165, as amended by Republic Act No. 10640. The Court emphasized that strict compliance with these procedures is vital to ensure the preservation of the chain of custody and, ultimately, the integrity of the confiscated drugs.
### Doctrine:
The case reiterates the importance of strict adherence to the chain of custody requirement under Section 21 of the Comprehensive Dangerous Drugs Act of 2002. This requirement ensures the integrity of confiscated, seized, and/or surrendered drugs and/or drug paraphernalia. Non-compliance with these procedures can lead to doubts about the identity of the corpus delicti, which is elemental in drug-related offenses, thereby warranting acquittal.
### Class Notes:
– Chain of Custody in Drug Cases: The case demonstrates the necessity of following the precise steps stated in Section 21 of Republic Act No. 9165 for maintaining the drug’s chain of custody, which includes immediate inventory and photography of seized items in the presence of specified individuals.
– Importance of Corpus Delicti: Establishing the integrity of the corpus delicti is crucial in proving drug-related offenses beyond a reasonable doubt.
– Non-Compliance with Protocol: The Supreme Court’s decision underscores that non-compliance with the mandated protocol regarding the handling of seized drugs can result in the acquittal of the accused, as it casts doubt on the evidence’s integrity.
### Historical Background:
This case reflects the judicial scrutiny applied in drug-related offenses in the Philippines, especially concerning the procedural requirements set by law to ensure fair and just treatment of the accused. It illustrates the balance the judiciary seeks to maintain between upholding the law against illegal drugs and safeguarding individual rights against possible procedural lapses by law enforcement.
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