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PEOPLE v. ANGELITA REYES Y GINOVE

FACTS:

On September 22, 2006, at around 4:00 PM, P/Insp. Alberto Gatus received information from a confidential informant about alleged drug activities involving a person known as "Babang" at a specific location in Barangay Tatalon, Quezon City. Subsequently, a team of police officers was dispatched to verify the information and conduct a surveillance and buy-bust operation the following day. P/Insp. Gatus provided PO2 Talosig with two marked P100 bills for the operation. Upon arrival at the location, the informant identified the person standing outside the house as "Babang," later identified as Angelita Reyes. PO2 Talosig, acting as a buyer, engaged in a transaction with Reyes, during which appellant Josephine Santa Maria facilitated the exchange by receiving the marked money and instructing Reyes to proceed with the sale. Upon receiving a plastic sachet containing a crystalline substance from Reyes, PO2 Talosig signaled the conclusion of the transaction, prompting the rest of the police team to move in. Consequently, both Reyes and Santa Maria were arrested, informed of their charges, and brought to the police station along with the seized evidence. The evidence was documented, photographed, and submitted for laboratory examination, leading to the filing of charges against Reyes and Santa Maria for the illegal sale of drugs. Both appellants denied the allegations and presented differing accounts of events on the day of the alleged crime, which were rejected by the trial court that found them guilty based on the police operation evidence.

ISSUES:

  1. Whether the arrest and search of the accused were invalid due to the alleged absence of a warrant, thereby rendering the evidence inadmissible.

  2. Whether the prosecution proved the guilt of the accused-appellant, Josephine Santa Maria, beyond reasonable doubt, with regard to the violation of Section 5, Article II of R.A. No. 9165.

RULING:

The Supreme Court found that the buy-bust operation was a legitimate and valid entrapment operation; hence, there was no need for a warrant before arresting and seizing evidence from the accused. However, the Court held that the prosecution failed to prove the guilt of the accused beyond reasonable doubt due to non-compliance with the mandatory requirements of Section 21 of R.A. No. 9165 concerning the chain of custody of the seized drug. The absence of representatives from the media and the National Prosecution Service, and the lack of justifiable reasons for this failure rendered the identification of the seized item questionable. Consequently, the accused-appellant was acquitted.

PRINCIPLES:

  1. Chain of Custody Rule - In drug-related cases, adherence to the chain of custody is critical to ensure the integrity and identity of the seized drug evidence.

  2. Buy-Bust Operation - Such operations are considered legitimate entrapment methods not requiring a warrant of arrest or search.

  3. Reasonable Doubt and Burden of Proof - The burden is always on the prosecution to establish the guilt of an accused beyond reasonable doubt, particularly in adhering to statutory procedural requirements.

  4. Justifiable Grounds for Non-compliance - Non-compliance with procedural safeguards can be excused only for justifiable reasons, which must be stated clearly and proven factually by the prosecution.