People v. Domado
REITERATIONFacts
The Antecedents: The appellant, Sitti Domado, was charged with violation of Section 5, Article II of R.A. No. 9165 for allegedly delivering 12 grams of methamphetamine hydrochloride (shabu). The prosecution presented evidence that an entrapment operation was conducted based on information from an arrested individual, Augustus, who claimed he could order shabu from his source. Augustus contacted his source, and an agreement was made to meet in Damortis, Sto. Tomas, La Union. An entrapment team proceeded to the location. Augustus was in a van with Police Senior Inspector Reynaldo L. Lizardo (PSI Lizardo). Three women, including the appellant, Jehan Sarangani, and Violeta Fernandez, arrived and boarded the van. Augustus asked if they brought the shabu, and one of the women, identified as Jehan, handed over an envelope containing three plastic sachets. Augustus gave these to PSI Lizardo, who confirmed they contained shabu and then arrested the three women. The seized items were brought to the police station, marked, inventoried, and sent for laboratory examination. The examination confirmed the presence of methamphetamine hydrochloride. Procedural History: The Regional Trial Court (RTC), Branch 31, Agoo, La Union, found the appellant guilty beyond reasonable doubt and sentenced her to life imprisonment and a fine of ₱500,000.00. The Court of Appeals (CA) affirmed the RTC decision in toto. The appellant appealed to the Supreme Court. The Petition: The appellant contended that the trial court erred in convicting her due to the prosecution's failure to establish the identity of the prohibited drugs, citing alleged lapses in the chain of custody, specifically the failure to mark the evidence immediately, the lack of clarity on who received the items at the police station, and the absence of an inventory in the presence of the accused and her counsel, a media representative, and a DOJ representative.
Issue(s)
Whether the prosecution sufficiently established the identity and integrity of the seized dangerous drugs despite alleged procedural lapses in the chain of custody. Whether the appellant's conviction for illegal delivery of dangerous drugs under R.A. No. 9165 is proper.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, upholding the conviction of the appellant for violation of Section 5, Article II of R.A. No. 9165. The penalty imposed, life imprisonment and a fine, was found to be within the range provided by law.
Ratio Decidendi
On the issue of the identity and integrity of the seized dangerous drugs: The Court ruled that the appellant's objections regarding the chain of custody were without merit. While acknowledging potential procedural lapses, such as the failure to photograph the seized items immediately and marking them at the police station rather than the exact scene of arrest, the Court emphasized that mere procedural lapses do not invalidate a seizure if the integrity and evidentiary value of the seized items are properly preserved. The Court noted that the seized shabu was marked with the initials "RLL" by PSI Lizardo, inventoried in the presence of a barangay kagawad and media representatives, and subsequently subjected to laboratory examination, which confirmed its identity as methamphetamine hydrochloride. The Court highlighted that the appellant did not contest the admissibility of the seized items during the trial, and the chain of custody, from seizure to laboratory examination and presentation in court, was sufficiently established through testimonial and documentary evidence. The Court reiterated the principle that the overriding concern is the maintenance of the integrity and evidentiary value of the seized drugs, and that substantial compliance with Section 21 of R.A. No. 9165 is sufficient when the integrity of the evidence is preserved. The Court also pointed out that the appellant's defense was one of avoidance (denying knowledge of the contents), not of tampering or planting of evidence, and that the circumstances of the case, with all parties in the van en route to the police station, minimized the possibility of evidence tampering before marking and inventory. On the issue of the appellant's conviction for illegal delivery of dangerous drugs: The Court found that the prosecution clearly showed that the delivery of the illicit drugs actually took place, and the authorities seized the shabu which passed through the proper investigatory and custodial chain until presented in court. The Court reiterated that Section 5, Article II of R.A. No. 9165 punishes not only the sale but also the mere act of delivering or distributing prohibited drugs. The Court found that the evidence presented adequately supported the finding that a delivery of illicit drugs occurred and that an unbroken chain of custody of the seized evidence was accounted for. The penalty imposed, life imprisonment and a fine, was found to be in accordance with Section 5 of R.A. No. 9165, as amended by R.A. No. 9346, which prohibits the imposition of the death penalty.
Main Doctrine
Non-compliance with procedural requirements in the custody and handling of seized dangerous drugs, such as failure to photograph or mark evidence immediately, does not render the seizure void or invalid, provided that the integrity and evidentiary value of the seized items are properly preserved, and there is substantial compliance with the law.