People v. Ulat
REITERATIONFacts
The Antecedents: On February 10, 2003, a confidential informant reported drug-pushing activities of one alias Pudong along Seabird Street, Barangay Rizal, Makati City. A buy-bust operation was organized by the Makati Anti-Drug Abuse Council (MADAC) Cluster 6 in coordination with the Makati Police Drug Enforcement Unit (Makati DEU). Armando Pol-ot, a MADAC volunteer, and the confidential informant acted as poseur-buyers. The pre-arranged signal for the back-up team was the poseur-buyer lighting a cigarette. At approximately 7:15 p.m., Pol-ot approached alias Pudong, introduced as a buyer needing shabu, and offered ₱100.00. Alias Pudong accepted the money, left, and returned with a small plastic sachet containing suspected shabu, which he handed to Pol-ot. Pol-ot then lit a cigarette, signaling the consummation of the transaction. PO1 Randy Santos and Rogelio Patacsil apprehended alias Pudong. The marked money was recovered from him. He was informed of his arrest and constitutional rights. The confiscated sachet was marked "EUA". Alias Pudong was brought to the DEU office for investigation, and a request for laboratory examination and drug test was prepared. The laboratory examination confirmed the substance to be Methylamphetamine Hydrochloride. A Joint Affidavit of Arrest was executed by PO1 Santos, Pol-ot, and Patacsil. Procedural History: The Regional Trial Court (RTC) of Makati, Branch 65, found appellant Edwin Ulat y Aguinaldo @ Pudong guilty beyond reasonable doubt for violation of Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). He was sentenced to life imprisonment and a fine of ₱500,000.00. The Court of Appeals affirmed the RTC Decision. Appellant appealed to the Supreme Court. The Petition: Appellant argued that the prosecution failed to prove his guilt beyond reasonable doubt due to inconsistent and contradicting testimonies of prosecution witnesses regarding the chain of custody of the illegal drug, thus failing to establish the corpus delicti and creating reasonable doubt.
Issue(s)
Whether the prosecution successfully established the identity and integrity of the corpus delicti through an unbroken chain of custody, thereby proving the offense charged beyond reasonable doubt.
Ruling
The Supreme Court reversed and set aside the assailed Decision of the Court of Appeals. For failure of the prosecution to prove his guilt beyond reasonable doubt, appellant Edwin Ulat y Aguinaldo was acquitted of the crime charged.
Ratio Decidendi
On Issue 1: The Supreme Court concluded that the prosecution failed to demonstrate with moral certainty that the identity and integrity of the prohibited drug, which constitutes the corpus delicti, had been duly preserved. A meticulous review of the records revealed material inconsistencies in the testimonies of the prosecution witnesses, specifically Armando Pol-ot and PO1 Randy Santos, regarding the crucial aspects of marking, inventory, and photographing of the seized illegal drug. Pol-ot initially testified that PO1 Santos marked the sachet and that an inventory report was prepared by Santos at the barangay hall, and also that the item was photographed with the accused present. However, his sworn affidavit contradicted his testimony regarding who marked the sachet, claiming he himself did it, which he dismissed as a "typographical error" while admitting he did not read the affidavit before signing it. More critically, PO1 Santos directly contradicted Pol-ot by testifying that Pol-ot marked the sachet, and emphatically denied making any inventory report or taking any photos of the seized items. These "conspicuous variances" in the testimonies of the apprehending team created serious doubt on their due care in the custody of the confiscated illegal drug and on the veracity of the buy-bust operation itself. The prosecution also failed to clearly disclose how the confiscated sachet passed hands from the apprehending officers until its receipt by the chemical analyst, thereby failing to present an unbroken chain of custody for the seized illegal drug. Citing Zaragga v. People and People v. Sitco, the Court reiterated that material inconsistencies regarding the chain of custody, coupled with non-compliance with Section 21 of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) concerning inventory and photographing, create reasonable doubt as to the identity of the corpus delicti, thereby warranting acquittal. The Court emphasized that while minor infractions may not be fatal, the extent of discrepancies in this case undermined the integrity of the object evidence and negated the presumption of regularity accorded to acts undertaken by the police officers.
Main Doctrine
The prosecution failed to establish an unbroken chain of custody for the seized illegal drug due to conflicting testimonies regarding its marking, inventory, and photographing, thereby failing to preserve its integrity and evidentiary value, which necessitates acquittal.