Sayson v. People
REITERATIONFacts
1. The Antecedents: Joseph Sayson y Parocha (petitioner) was charged with Illegal Sale and Illegal Possession of Dangerous Drugs under Sections 5 and 11, Article II of Republic Act No. 9165, as amended. The charges stemmed from an incident on July 25, 2016, where the prosecution alleged he possessed 0.12 grams of methamphetamine hydrochloride and sold 0.02 grams of the same substance. The defense denied the accusations, claiming the petitioner was falsely implicated by police officers. 2. Procedural History: The Regional Trial Court (RTC), Branch 228, Quezon City, found the petitioner guilty beyond reasonable doubt of Illegal Possession of Dangerous Drugs (Section 11, Article II of RA 9165) and sentenced him to twelve (12) years and one (1) day to fourteen (14) years imprisonment, with a fine of P300,000.00. He was acquitted of the charge of Illegal Sale of Dangerous Drugs (Section 5, Article II of RA 9165). The Court of Appeals (CA) affirmed the RTC's decision in its entirety. The CA ruled that the elements of illegal possession were proven, the marking of seized items at the barangay hall was justified due to a commotion, and the buy-bust team made earnest efforts to secure witnesses. 3. The Petition: The petitioner filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, seeking to annul and set aside the CA's decision and resolution. The core of the petition argues that the CA erred in affirming his conviction for Illegal Possession of Dangerous Drugs. Specifically, the petitioner contends that the prosecution failed to preserve the integrity and evidentiary value of the seized items due to non-compliance with the chain of custody requirements, particularly the mandatory witness requirement during the marking and inventory of the confiscated drugs.
Issue(s)
Whether the Court of Appeals erred in affirming the petitioner's conviction for Illegal Possession of Dangerous Drugs, considering the requirements of chain of custody. Whether the prosecution sufficiently established the chain of custody of the seized dangerous drugs, particularly regarding compliance with the witness requirement under Section 21 of RA 9165, as amended, and whether deviations from this requirement were justified.
Ruling
The petition is granted. The Decision dated March 14, 2019, and the Resolution dated September 12, 2019, of the Court of Appeals are reversed and set aside. Petitioner Joseph Sayson y Parocha is acquitted of Illegal Possession of Dangerous Drugs under Section 11, Article II of Republic Act No. 9165, as amended. The Director of the Bureau of Corrections is ordered to immediately release the petitioner unless he is held for other lawful reasons.
Ratio Decidendi
On the Issue of Illegal Possession of Dangerous Drugs and Chain of Custody: The Court reiterated that for a conviction of Illegal Possession of Dangerous Drugs under Section 11, Article II of RA 9165, the prosecution must prove beyond moral certainty that the accused possessed a prohibited drug, that such possession was not authorized by law, and that the accused freely and consciously possessed the drug. Crucially, the identity of the dangerous drug must be established by accounting for each link in the chain of custody from seizure to presentation in court. The records showed a lack of compliance with the witness requirement under Section 21 of RA 9165, as amended by RA 10640. The inventory was conducted in the presence only of a barangay desk officer. The prosecution's mere allegation that attempts were made to contact the mandatory witnesses, without showing genuine and sufficient efforts to secure their presence, is insufficient to justify the deviation from the mandatory directives of the law. Consequently, the integrity and evidentiary value of the seized items, which constitute the corpus delicti, were compromised. Therefore, the conviction must be overturned.
Main Doctrine
The integrity and evidentiary value of seized dangerous drugs are compromised due to non-compliance with the chain of custody requirements, specifically the mandatory witness requirement under Section 21 of RA 9165, as amended by RA 10640, leading to acquittal.