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PEOPLE v.

SEGUNDO
G.R. No. 205614 | 26 July 2017
Custody and Disposition of Confiscated, Seized and/or Surrendered Dangerous Drugs, Plant Sources of Dangerous
Drugs, Controlled Precursors and Essential Chemicals, Instruments/Paraphernalia and/or Laboratory Equipment
under the Comprehensive Dangerous Drugs Act

DOCTRINE: Sec. 21, par. 1 of RA 9165 provides for a definite procedure relevant to the confiscation and handling of prohibited
drugs. Compliance with the chain of custody is necessary due to the unique nature of narcotics.

FACTS:
 It was alleged that Jaime Segundo willfully, unlawfully and feloniously sold to poseur-buyer, POI Cesar Claveron, (1) heat-sealed
transparent plastic sachet with markings, "JSI- 1" containing 0.03 gram of "shabu"
 Segundo assailed the broken chain of custody in handling the alleged confiscated shabu and contends that the testimonies of the
police officers were not categorical and reliable.
 SPO1 Balzamo admitted that no photographs were taken on the confiscated items and PO3 Occeña confessed that "no members
of the media and representative from the barangay were present when the said items were allegedly marked.

ISSUE: Whether or not Segundo may be acquitted because of the officers’ noncompliance with the chain of custody. (Yes)

RULING:
 The prosecution offered testimonies to establish the identity of the buyer and seller, as well as the consideration that sustained the
alleged deal and how the sale had transpired. It failed, however, to comply with the chain of custody that would supposedly ensure
that the miniscule amount of 0.03 grams of shabu offered as evidence in court was the one retrieved from Segundo at the time of
the operation.
 As the law enforcers who planned and conducted the operation, they should know the details of the incident. In this case, however,
the police officers posited contradictory statements, casting uncertainty on the veracity of their narrative.
 Although the miniscule quantity of confiscated illicit drugs is solely by itself not a reason for acquittal, this instance accentuates the
importance of conformity to Section 21 that the law enforcers in this case miserably failed to do so. If initially there were already
significant lapses on the marking, inventory, and photographing of the alleged seized items, a doubt on the integrity of the corpus
delicti concomitantly exists.
 Thus, there is failure on the part of the prosecution to prove Segundo’s guilt beyond reasonable doubt.