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PEOPLE v. LAHMODIN AMERIL Y ABDUL

FACTS:

Lahmodin Ameril was convicted of violating Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002, for illegally selling drugs. Special Investigator Rolan Fernandez testified that Ameril was reported by a confidential informant as a drug dealer. Fernandez acted as a buyer and arranged a meeting with Ameril to purchase shabu. During the meeting at Solanie Hotel, Ameril showed Fernandez three sachets of white crystalline substance in exchange for money. Fernandez then revealed his identity and arrested Ameril. The seized items were tested positive for shabu. Ameril denied the allegations, claiming he was preparing for a job application in Jeddah.

Ameril's appeal argued that the prosecution failed to prove the corpus delicti and pointed out inconsistencies in the markings of the seized drugs. The Court of Appeals upheld Ameril's conviction, stating that the chain of custody remained intact and the accused was informed of the crime charged against him. The Supreme Court reviewed the case, emphasizing the importance of establishing the elements of illegal drug sale, including proving the transaction and presenting the corpus delicti. The chain of custody rule and Section 21 of RA No. 9165 were discussed as crucial to maintaining the integrity of seized drugs.

Another case involved Roberto Balao, who was charged with violating Section 11, Article II of the Comprehensive Dangerous Drugs Act. The police received information from a confidential informant that Balao was selling shabu in his house. On the same day, the police executed a search warrant and forcibly entered Balao's house. They found sachets of shabu in a cabinet in the living room. Balao was arrested and brought to the police station with the seized items. He argued that the police illegally entered his house and planted the drugs, pointing out the absence of proper inventory and photographs of the seized items. The trial court found Balao guilty, which was affirmed by the Court of Appeals. Balao appealed to the Supreme Court.

ISSUES:

  1. Whether the chain of custody requirement under Article II, Section 21 of Republic Act No. 9165 was complied with.

  2. Whether the discrepancy in the markings of the seized items raises doubt on the identity of the drugs.

  3. Whether there was a discrepancy in the markings of the seized items.

  4. Whether the procedural lapses in handling and identifying the seized items raise doubts on the authenticity of the items presented in court.

  5. Whether the prosecution has proven the guilt of the accused beyond reasonable doubt.

  6. Whether the arresting officers complied with the requirements of chain of custody.

RULING:

  1. The chain of custody requirement under Article II, Section 21 of Republic Act No. 9165 was not complied with. Although the court found that the seized items were properly marked, photographed, and inventoried in the presence of witnesses from the barangay and the media, there was no evidence of the immediate physical inventory and photograph of the seized items conducted in the presence of the accused or his representative as required by the law. Thus, the integrity and evidentiary value of the seized items were not properly preserved.

  2. The discrepancy in the markings of the seized items raises doubt on the identity of the drugs. The seized drugs are considered the corpus delicti of the crime, and its identity must be proved beyond reasonable doubt. When there is doubt on its identity, conviction cannot be sustained. In this case, the evidence showed that the accused sold three plastic sachets with the markings "LLA-1," "LLA-2," and "LLA," but the information filed against the accused indicated that he sold three sachets with the markings "LAA," "LAA-2," and "LAA." This discrepancy casts doubt on whether the items presented in court were the same ones taken from the accused upon arrest.

  3. There was a discrepancy in the markings of the seized items. The markings on the seized items presented in court were different from the markings testified to by the arresting officer and the investigator. This discrepancy raises doubts on the authenticity of the items.

  4. The procedural lapses in the handling and identification of the seized items, as well as the unexplained discrepancy in their markings, raise doubts on whether the items presented in court were the exact same items that were taken from the accused. These major lapses are fatal to the prosecution's case.

  5. The accused is acquitted for failure of the prosecution to prove guilt beyond reasonable doubt.

  6. The arresting officers failed to comply with the chain of custody requirement, negating the presumption of regularity in their favor.

PRINCIPLES:

  • Compliance with the chain of custody requirement is essential in drug cases. Failure to comply with this requirement may render the seizure and custody of the drugs as void and invalid.

  • The chain of custody must be shown with sufficient completeness to render it improbable that the original item has been tampered with or substituted. This standard is more stringent in cases involving narcotic substances, which are not readily identifiable.

  • The presumption of regularity in the performance of official duty "stands only when no reason exists in the records by which to doubt the regularity of the performance of official duty" and is not stronger than the presumption of innocence in favor of the accused. (People v. Segundo)

  • The presumption of regularity in the performance of official duty cannot affect the constitutional presumption of innocence enjoyed by an accused. The evidence of the prosecution must be strong enough to establish guilt beyond reasonable doubt. (People v. Mirantes)

  • The prosecution has the burden of proof to establish the guilt of the accused beyond reasonable doubt.

  • The onus probandi on the prosecution is not discharged by casting doubts upon the innocence of the accused, but by eliminating all reasonable doubts as to his guilt.

  • The presumption of regularity in favor of arresting officers can be negated if there are discrepancies in documentation and non-compliance with the requirements of chain of custody.