People v. Relato
REITERATIONFacts
The Antecedents: Darwin Relato y Ajero was charged with selling two plastic sachets of methamphetamine hydrochloride, commonly known as "shabu," weighing 0.0991 grams, for ₱500.00, during a buy-bust operation conducted by police officers in Barangay Aquino, Bulan, Sorsogon. The prosecution alleged that Relato willfully, unlawfully, and feloniously sold the prohibited drugs without proper authorization. Relato denied the charges, claiming he was framed and that the drugs were planted on him after he was apprehended and searched at the police station. Procedural History: Following his arrest on August 29, 2002, Relato was charged on August 30, 2002, in the Regional Trial Court (RTC), Branch 65, Bulan, Sorsogon. After pleading not guilty, a trial ensued. On August 9, 2004, the RTC convicted Relato of violating Section 5 of Republic Act No. 9165 and sentenced him to life imprisonment and a fine of ₱500,000.00. Relato appealed this decision to the Court of Appeals (CA), which affirmed the RTC's conviction on May 24, 2006. Relato then elevated the case to the Supreme Court. The Petition: Relato petitioned the Supreme Court, arguing that the Court of Appeals erred in affirming his conviction, contending that his guilt was not proven beyond reasonable doubt and that the prosecution failed to establish a proper chain of custody for the seized illegal drugs. The Supreme Court reviewed the case and found significant procedural lapses in the handling of the seized evidence, specifically noting the failure to immediately mark the drugs, photograph them in the presence of the accused and required witnesses, and the absence of representatives from the media and the Department of Justice during the inventory. The Court concluded that these lapses cast serious doubt on the integrity and authenticity of the evidence, leading to the reversal of the conviction and acquittal of Relato.
Issue(s)
Whether the prosecution sufficiently established the chain of custody of the seized dangerous drugs. Whether the accused-appellant’s guilt was proven beyond reasonable doubt.
Ruling
The Supreme Court reversed the decision of the Court of Appeals and acquitted Darwin Relato y Ajero due to the failure of the State to establish his guilt beyond reasonable doubt. The Court directed the immediate release of Relato from detention unless he is being held for other lawful causes.
Ratio Decidendi
On the issue of chain of custody: The Court found that the prosecution failed to comply with the statutory rules on preserving the chain of custody of confiscated prohibited drugs as mandated by Section 21 of Republic Act No. 9165 and its Implementing Rules and Regulations (IRR). Specifically, the buy-bust team failed to immediately mark the seized shabu at the scene of the crime in the presence of the accused and witnesses, no photograph of the seized items was taken, and the marking at the police station was not shown to have been done in the presence of Relato or his representative. Furthermore, no representatives from the media, Department of Justice, or any elected official were present during the inventory and signing of the inventory report. The Court emphasized that the marking of the seized items immediately after seizure is the starting point of the custodial link and is crucial for ensuring the integrity of the chain of custody. While the IRR provides a saving mechanism for non-compliance, it requires a justifiable explanation for the lapse and a credible showing that the integrity and evidentiary value of the seized items were preserved. In this case, the prosecution offered no explanation for the failure to mark the items immediately, nor did it credibly show efforts to keep the shabu intact while in transit. On the issue of proof beyond reasonable doubt: These procedural lapses cast serious doubt on the identity and integrity of the shabu presented as evidence, thus failing to establish the corpus delicti. Consequently, the State failed to discharge its basic duty of proving the guilt of the accused beyond reasonable doubt, making Relato's defense of frame-up plausible in light of the weakness of the prosecution's evidence.
Main Doctrine
The failure of the prosecution to establish the chain of custody of the confiscated prohibited drugs, due to procedural lapses in marking, inventory, and photographing the seized items, creates serious doubt on the identity and integrity of the evidence, thereby failing to prove the corpus delicti beyond reasonable doubt.