**Facts:**
– On September 12, 2005, at approximately 4:00 PM, a male informant reported to the District Anti-Illegal Drug Special Task Group (DAID-SOTG) in Quezon City that a person named “Ningning” was selling illegal drugs at 22-C Salvador Drive, Balonbato, Quezon City.
– SPO2 Dante D. Nagera endorsed the matter to Col. Gerardo B. Ratuita for a buy-bust operation.
– A buy-bust team was formed comprising PO3 Leonardo R. Ramos (poseur-buyer), PO1 Peggy Lynne V. Vargas, PO1 Teresita B. Reyes, PO1 Alexander A. Jimenez, and SPO2 Nagera.
– Before deployment, PA1 Reyes filed a Pre-Operation Report with the Philippine Drug Enforcement Agency (PDEA).
– At approximately 9:35 PM, the team arrived at the target area in three vehicles.
– PO3 Ramos and the informant approached the house while the rest of the team positioned themselves nearby.
– The informant identified “Gigi” as Joel Clara y Buhain (Joel), Ningning’s uncle.
– Upon transaction initiation, PO3 Ramos handed P200 to Joel; Joel went upstairs, retrieved the drugs from Ningning, and handed it to PO3 Ramos.
– Following the transaction, PO3 Ramos signaled the team, leading to Joel’s attempted but thwarted escape and subsequent arrest while Ningning escaped.
– No physical evidence was recovered from Joel during the frisk; the marked money was with Ningning.
– A small sachet of suspected shabu was marked by PO1 Jimenez at the police station, which was later confirmed by a forensic chemist to be methamphetamine hydrochloride.
– Joel was charged with Illegal Sale of Dangerous Drugs under Section 5, Article II of R.A. No. 9165.
Procedural Posture:
– Joel pleaded not guilty during arraignment.
– During trial, inconsistencies emerged in testimonies of prosecution witnesses concerning material aspects of the buy-bust operation, particularly about the marking and custody of the seized drugs.
– The Regional Trial Court (RTC) found Joel guilty beyond a reasonable doubt, sentencing him to life imprisonment and imposing a fine of P500,000. The Court of Appeals (CA) affirmed the conviction.
**Issues:**
1. Were the elements of illegal sale of prohibited drugs established beyond a reasonable doubt?
2. Was the chain of custody and integrity of the seized evidence properly preserved?
3. Should the presumption of regularity in law enforcement officers’ duties prevail over the accused’s presumption of innocence?
**Court’s Decision:**
1. **Identity of Buyer and Seller, Object and Consideration:**
– Inconsistent testimonies by officers regarding who marked the plastic sachet of shabu and its handling.
– Doubts arose whether the transaction occurred as claimed due to varying accounts on critical details.
2. **Chain of Custody:**
– The prosecution faltered in demonstrating a clear chain of custody. Testimonies conflicted on the marking, handling, and who had possession of the shabu at different times.
– Failure to maintain an unbroken chain of custody creates reasonable doubt regarding the identity of the seized evidence.
3. **Presumption of Regularity vs. Presumption of Innocence:**
– The presumption of regularity in police procedure was overcome by substantial inconsistencies and procedural lapses.
– The inconsistencies affected the integrity of the evidence and the regularity of police conduct, thereby necessitating the presumption of innocence for Joel.
The Supreme Court ruled to reverse the CA’s decision and acquit Joel due to reasonable doubt, focusing on the flawed chain of custody and erratic witness accounts.
**Doctrine:**
– “Chain of Custody Rule”: To convict for illegal drug sale, a clear, unbroken chain of custody of the seized item from the point of acquisition through its presentation in court must be demonstrated.
– “Presumption of Innocence”: Overrides the presumption of regularity in law enforcement when significant inconsistencies or procedural lapses are present.
**Class Notes:**
Key legal concepts:
– **Illegal Sale of Dangerous Drugs Elements:** (1) Identity of buyer, seller, object, and consideration; (2) Delivery and payment.
– **Chain of Custody:** Ensuring integrity involves (1) seizure and marking; (2) turnover to investigating officer; (3) forensic laboratory examination; (4) submission to court.
– **Presumption of Innocence vs. Regularity in Duty:** The accused’s inherent innocence takes precedence unless irrefutable proof of lawful conduct and evidence integrity exists.
Relevant Statutes:
– **R.A. No. 9165, Section 5:** Comprehensive Dangerous Drugs Act of 2002 on the illegal sale of drugs.
– **Rules of Court, Rule 133, Section 2:** Regarding proof necessary for conviction beyond reasonable doubt.
**Historical Background:**
This case falls in the broader context of the Philippines’ war on drugs post-R.A. No. 9165, highlighting challenges in law enforcement against the backdrop of procedural safeguards to prevent miscarriages of justice. The judicial emphasis on strict adherence to the chain of custody and overcoming reasonable doubt reflects the legal system’s commitment to justice and due process amidst nationwide anti-drug campaigns.
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