CASE DIGEST
PEOPLE V. BALUYOT Y
BIRANDA
G.R. No. 243390, October
5, 2020
SECOND DIVISION, HERNANDO
J.
RA 9165, Illegal
Sale, Chain of Custody Rule
Doctrine: Strict compliance with the chain of custody rule is crucial to preserve the integrity of the evidence in drug-related cases. Failure to clearly establish the chain of custody from the time of seizure to the time of presentation in court, will raised doubts about the integrity and identity of the evidence, which will warrant acquittal.
Alex Baluyot was charged with 2 separate information relating to violation of dangerous drugs law based on a buy-bust operation conducted by PDEA officers. The prosecution presented evidence of the sale and positive drug test results. The RTC found him guilty of illegal sale. However, the RTC acquitted him of illegal possession of dangerous drugs due to uncertainty in establishing the identity of the seized specimens. CA denied the appeal but modified the ruling to make Alex ineligible for parole.
Alex now appeals to the Supreme Court,
arguing that the chain of custody rule was not followed, and the testimonies of
the PDEA officers were inconsistent. The OSG, maintains that the integrity of
the seized drugs was preserved, and the testimonies of the prosecution witnesses
were credible. The case is now before the Supreme Court for review.
Whether or not Alex is guilty of Illegal Sale of
Dangerous Drugs.
NO.
The appeal of Alex Baluyot is granted, and he is acquitted of the charge of
violating Section 5, Article II of RA 9165 (Illegal Sale of Dangerous Drugs).
The court found that the prosecution successfully established the elements of
the crime through testimonies and evidence. However, there was a failure to
properly observe the chain of custody rule during the operation, as only two
witnesses were present during the marking of the seized items instead of the
required three. The absence of a representative from the DOJ was not justified,
and the prosecution failed to show justifiable grounds for non-compliance with
the three-witness requirement. This lapse compromised the integrity of the
seized items, creating reasonable doubt on Alex's guilt. Therefore, he is
acquitted.
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