People v. Mazo
REVERSALFacts
The Antecedents: Nico Mazo y Ybañez and Joey Domdoma y Abletes were charged with illegal sale and possession of dangerous drugs under Republic Act No. 9165. The charges stemmed from a buy-bust operation conducted by the Station Anti-Illegal Drugs-Special Operations Task Group in Makati City on January 13, 2017. During the operation, Nico allegedly sold methamphetamine hydrochloride (shabu) to a poseur-buyer, and both Nico and Joey were subsequently arrested. Nico was also found to be in possession of additional sachets of the same substance. Procedural History: The Regional Trial Court (RTC) convicted Nico and Joey for illegal sale of dangerous drugs and Nico for illegal possession of dangerous drugs. Joy, a co-accused, was acquitted. The RTC found the prosecution's version of events credible and the chain of custody of the seized evidence to be intact. Aggrieved, Nico and Joey appealed to the Court of Appeals (CA), arguing that they were framed and that the chain of custody was violated. The CA affirmed the RTC's decision, finding that the integrity and evidentiary value of the seized drugs were preserved. Subsequently, the Supreme Court dismissed their appeal. This led to the filing of the present Motion for Reconsideration. The Petition: In their Motion for Reconsideration, the accused-appellants, Nico Mazo y Ybañez and Joey Domdoma y Abletes, argue that the police officers failed to observe the proper handling and custody of the seized items, thereby breaking the chain of custody. They contend that the prosecution did not satisfactorily establish the movement and custody of the seized drugs from confiscation to their presentation in court, raising doubts about the integrity and evidentiary value of the corpus delicti. The Supreme Court, in its Resolution, granted the motion, reversed its previous dismissal, and acquitted the accused-appellants due to the prosecution's failure to prove an unbroken chain of custody.
Issue(s)
Whether the prosecution established an unbroken chain of custody over the seized dangerous drugs, thus proving the corpus delicti. Whether, considering the integrity of the evidence, the accused are guilty beyond reasonable doubt of illegal sale and possession of dangerous drugs.
Ruling
The motion for reconsideration is GRANTED. The Court's July 15, 2019 Resolution is REVERSED and SET ASIDE. Nico Mazo y Ibañez and Joey Domdoma y Abletes are ACQUITTED in Criminal Case Nos. R-MKT-17-00179-CR and R-MKT-17-00180-CR, and are ORDERED IMMEDIATELY RELEASED from detention, unless they are being lawfully held for another cause.
Ratio Decidendi
On the issue of the unbroken chain of custody: The Court held that the prosecution failed to establish an unbroken chain of custody over the seized dangerous drugs, which constitutes the corpus delicti in illegal sale and possession cases. The integrity and evidentiary value of the substance must be satisfactorily established through a continuous movement and custody from confiscation to presentation in court. The Court found several lapses in the chain of custody in this case. Firstly, the marking of the dangerous drugs was not adequately accounted for; PO1 Amante testified that the drugs were "later marked" without providing details on where and when this occurred, leaving room for suspicion of tampering or switching. Secondly, the inventory and photograph of the seized items were not made immediately at the place of arrest but at the barangay hall, with only a general statement that the arrest area was hostile, without elaboration on security threats. Thirdly, the absence of a representative from the National Prosecution Service or the media during the inventory and photograph, with only an elected public official present, cast serious doubt on the integrity of the confiscated items. The Court noted that the barangay official had no personal knowledge of the confiscation. The presence of insulating witnesses is crucial not only during inventory but, more importantly, at the time of warrantless arrest to belie doubts as to the source, identity, and integrity of the seized drugs. The prosecution failed to show earnest efforts to secure these required witnesses, rendering their absence unjustifiable. On the issue of reasonable doubt and guilt: Consequently, the presumption of regularity in the performance of duty cannot prevail over the constitutional right to be presumed innocent when the performance of duty is tainted with such irregularities. The Court reiterated that lax handling of the corpus delicti by law enforcers compromises the integrity of the evidence, necessitating acquittal. Therefore, the accused cannot be found guilty beyond reasonable doubt.
Main Doctrine
The prosecution failed to establish an unbroken chain of custody of the seized dangerous drugs due to irregularities in the marking, inventory, and presence of insulating witnesses, warranting the acquittal of the accused.