People vs. Relato

G.R. No. 173794 (January 18, 2012)

Darwin Relato y Ajero was acquitted due to prosecution's evidence chain lapses, emphasizing procedural compliance.

Facts:

Darwin Relato y Ajero was arrested on August 29, 2002, during a buy-bust operation conducted by the Bulan Police in Sorsogon. The operation was initiated after a police asset informed PO3 Sonny Evasco that Relato would be selling illegal drugs that night. Following the tip, a team was formed, and a marked P500.00 bill was prepared for the transaction. At approximately 11:00 PM, Relato was apprehended after selling two plastic sachets of methamphetamine hydrochloride (shabu) to the poseur buyer, who was the police asset. The buy-bust team seized the marked bill and the two sachets from Relato.

After the arrest, the sachets were marked with the initials of SPO1 Elmer Masujer at the police station, and a forensic examination confirmed that the contents were indeed methamphetamine hydrochloride. Relato, however, denied the charges, claiming he was framed. He asserted that he was on his way to a wake when he was suddenly arrested without any drugs being found on him. He alleged that the police planted the evidence against him.

The Regional Trial Court (RTC) found Relato guilty of violating the Comprehensive Dangerous Drugs Act of 2002, sentencing him to life imprisonment and a fine of P500,000. Relato appealed the decision, arguing that the RTC erred in its assessment of the evidence and the credibility of witnesses.

Legal Issues:

  1. Whether the prosecution established the chain of custody of the seized drugs in accordance with the requirements of Republic Act No. 9165.
  2. Whether the procedural lapses in the handling of the evidence compromised the integrity of the prosecution's case against Relato.

Arguments:

  • Prosecution's Argument: The prosecution maintained that the buy-bust operation was conducted lawfully and that the evidence presented, including the marked buy-bust money and the seized sachets, was sufficient to establish Relato's guilt beyond a reasonable doubt. They argued that the testimonies of the police officers were credible and consistent.

  • Defense's Argument: Relato's defense contended that the prosecution failed to comply with the procedural requirements for the handling of seized drugs, particularly the immediate marking and inventory of the evidence in the presence of witnesses. They argued that these lapses raised serious doubts about the integrity and authenticity of the evidence, thereby undermining the prosecution's case.

Court's Decision and Legal Reasoning:

The Supreme Court reversed the decision of the Court of Appeals, acquitting Relato due to the prosecution's failure to establish his guilt beyond a reasonable doubt. The Court emphasized the importance of the chain of custody in drug-related cases, as outlined in Section 21 of Republic Act No. 9165. The Court noted several procedural lapses by the buy-bust team:

  1. No photographs of the seized drugs were taken at the time of the seizure.
  2. The sachets were not marked immediately after the seizure in the presence of Relato or any witnesses.
  3. There was no representative from the media, the Department of Justice, or any elected official present during the inventory process.

The Court highlighted that these lapses created uncertainty regarding the identity and integrity of the seized drugs, which are critical in establishing the corpus delicti in drug cases. The absence of proper documentation and adherence to the required procedures led to doubts about whether the evidence presented in court was indeed the same as that seized from Relato.

The Court concluded that the prosecution's failure to establish a clear chain of custody and the integrity of the evidence warranted Relato's acquittal, particularly in light of his plausible defense of being framed.

Significant Legal Principles Established:

  1. The chain of custody is crucial in drug-related prosecutions to ensure the integrity and authenticity of the evidence.
  2. Strict compliance with the procedural requirements for the handling of seized drugs is necessary; lapses can lead to reasonable doubt regarding the evidence's integrity.
  3. The burden of proof lies with the prosecution to establish the guilt of the accused beyond a reasonable doubt, including proving the corpus delicti.