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PEOPLE v. MARCELO SANCHEZ Y CALDERON

FACTS:

Marcelo Sanchez y Calderon (appellant) was charged with violation of Section 5, Article II of Republic Act No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002. He pleaded not guilty during the arraignment.

The prosecution presented witnesses who testified that a buy-bust operation was conducted after receiving information that appellant was engaged in the illegal drug trade. During the operation, the poseur-buyer handed the buy-bust money to appellant in exchange for a plastic sachet of suspected shabu. Appellant was then arrested, and the seized items were marked and photographed. The seized items were later confirmed to be methylamphetamine hydrochloride, a dangerous drug.

Appellant, on the other hand, denied the charge and claimed that he was arbitrarily arrested inside his house and accused of selling illegal drugs. He alleged that the police officers searched for someone else and when they did not find that person, they arrested him instead.

The Regional Trial Court (RTC) convicted appellant of the offense charged and sentenced him to life imprisonment and a fine. The Court of Appeals (CA) subsequently affirmed the RTC's decision. Appellant appealed his conviction before the Supreme Court, arguing that the evidence against him was inadmissible because he was arrested without a warrant.

The Supreme Court required the parties to submit their respective supplemental briefs. Appellant adopted his Appellant's Brief filed before the CA as his supplemental brief, while the Office of the Solicitor General chose not to file a supplement to its Appellee's Brief.

ISSUES:

  1. Whether the prosecution was able to establish the identity of the corpus delicti and the unbroken chain of custody of the seized drugs.

  2. Whether the discrepancy in the markings on the seized drugs affects the integrity of the evidence.

  3. Whether the identity and integrity of the seized dangerous drugs were preserved.

  4. Whether the discrepancy in the markings of the seized dangerous drugs raises reasonable doubt on their identity.

  5. Whether the prosecution established with certainty that the illegal substance presented in court as evidence is the same substance illegally possessed and sold by the appellant.

  6. Whether the appellant should be acquitted based on reasonable doubt.

RULING:

  1. The Court is not convinced that the identity of the corpus delicti was properly established, and there is reasonable doubt as to the alleged unbroken chain of custody. The discrepancy in the markings on the seized drugs affects the integrity of the evidence.

  2. The Supreme Court held that the identity and integrity of the seized dangerous drugs were not preserved and that the discrepancy in the markings raises reasonable doubt on their identity.

  3. The appeal is granted. The Decision of the Court of Appeals affirming the Decision of the trial court is reversed and set aside. The appellant is acquitted based on reasonable doubt. The Director of the Bureau of Corrections is ordered to cause the immediate release of the appellant, unless he is lawfully held for another cause.

PRINCIPLES:

  • To secure a conviction for illegal sale of dangerous drugs, the prosecution must establish the identity of the buyer and seller, the object of the sale and its consideration, and the delivery of the thing sold and the payment therefor.

  • The chain of custody rule ensures that doubts concerning the identity of the evidence are removed, and it must be shown that the integrity and identity of the seized drugs have been duly preserved.

  • The marking of the seized item is crucial in proving an unbroken chain of custody, as it is the starting point in the custodial link that succeeding handlers of the evidence will use as a reference point.

  • The prosecution has the duty to prove every link in the chain of custody, from the moment the dangerous drug was seized until it is offered in court as evidence.

  • Discrepancies in the markings on the seized drugs may affect the integrity and admissibility of the evidence.

  • The chain of custody of seized dangerous drugs is crucial in proving their identity and integrity.

  • The marking of seized evidence separates it from other similar evidence and ensures its proper identification throughout the criminal proceedings.

  • The first link in the chain of custody, which involves the seizure and marking of the illegal drugs, is crucial in establishing the subsequent links.

  • Inconsistencies or discrepancies in the markings of seized drugs, when unexplained, can cast doubt on the identity of the drugs and are fatal to the prosecution's case.

  • Conviction in drug cases cannot be sustained if there is persistent doubt on the identity of the drugs. The identity of the drugs must be established with moral certainty.

  • The prosecution must establish with certainty that the substance presented in court as evidence is the same substance illegally possessed and sold by the accused.

  • The guilt of the accused must be proven beyond reasonable doubt in criminal cases.