People v Zakaria (PS.
sorry ang haba, medyo relevant kasi yung case) room before being shown sachets of shabu supposedly recovered from them.
Topic: Admissibility of Evidence
Doctrine: The chain of custody is crucial in establishing the link between the shabu
confiscated from the accused and the evidence presented to the court for its appreciation.
The corpus delicti was not credibly proven because the Prosecution did not establish an
unbroken chain of custody, resulting in rendering the seizure and confiscation of the shabu
open to doubt and suspicion. Hence, the incriminatory evidence should not pass judicial
scrutiny.
Facts:
(1) Version of the prosecution:
- PO2 Aninias declared that a confidential informant went to the PDEA Office on
Camp Vicente Lim in Laguna and informed the Chief Supt. That he had entered
into a drug deal for 35g of shabu worth P98k with accused herein Sps Danny
and Joana to take place in Taguig. On the basis of such information, a buy-bust
team was formed with PO2 Aninias as poseur-buyer. P500 bill was given to
Aninias, who wrote his initials LLA on the bill, and then placed the marked bill
on the bundle of boodle money that seemingly amounted to P98k, placed inside
a white envelope.
- After surveying the target area to confirm the drug activities, the confidential
informant contracted Danny to tell him that he had a buyer. They agreed to
have the deal at the target area. A pre-operation report was then prepared and
coordinated with the PDEA National Office.
- Using a Toyota Revo and Mitsubishi Adventure, the buy bust team arrived at
the target area. Not long after, Danny arrived and got on board the Revo, which
was driven by Aninias. Aninias was introduced to Danny as the buyer. Danny
said that the shabu was with his wife Joana, and got out of the Revo to fetch
her. Later, the sps returned and Danny pulled 3 sachets of white crystalline
substance from his pocket and handed it over to Aninias, who turned over the
white window envelope to Joana and forthwith made a missed call to PO3
Valdez, signaling the consummation of the transaction. As Danny was about to
count the money, Aninias drew and pointed his gun at the sps and the rest of
the team rushed in and arrested them.
- Aninias immediately placed his initials on the 3 sachets of shabu while Valdez
recovered the boodle money from Joana. The team brought the sps to Camp
Vicente for investigation while Aninias turned over the seized sachets to PNP
crime lab, which yielded positive results of the drug.
(2) Version of defense
- Joana alleged, and Danny corroborated, that on the said date, she went to fetch
her daughter from school and upon arriving home, she noticed her husband
lying face down inside their bedroom with several men around him, one of them
stepping on his head. The men then brought the sps to Camp Vicente Lim on
board the Revo driven by Aninias, and Valdez demanded 100k in exchange for
their release. She failed to give the money and they were detained in a small
She protested and argued that they were not selling shabu.
(3) RTC: Convicted both accused for violation of Sec 5 of RA 9165 (illegal sale of
dangerous drugs)
(4) CA: Affirmed.
(5) Only Danny filed a timely notice of appeal, resulting in the CA decision becoming final
and executory as to Joana.
(6) Danny alleged:
- Members of the buy-bust team did not fully explain to him his constitutional
rights
- State did not establish the origin of the seized drugs and did not prove the chain
of custody had been observed
- Guilt was not established beyond reasonable doubt
Issue: W/N the chain of custody rule was observed as to credibly prove the corpus delicti.
(NO)
Held:
(1) In every prosecution of illegal sale of dangerous drugs, the presentation of the seized
dangerous drugs as evidence in court is indispensable. It is essential that the identity
of the drugs be established beyond reasonable doubt; that the drugs bought during
the buy-bust ope are the same ones offered in court. The chain of custody
requirement performs this function as it ensures that unnecessary doubts concerning
the identity of the evidence are removed. Moreover, to discharged its overall duty of
proving the guilt of the accused beyond reasonable doubt, the State bears the burden
of proving the corpus delicti or the body of the crime, which is not complied if there
doubts as to the authenticity or there are gaps in the chain of custody.
(2) In People v Belocura:
- The chain of custody req applied by virtue of the universal need to competently
and sufficiently establish the corpus delicti. It is basic under the ROC that
evidence, to be relevant, must have a logical relation to the facts in issue to be
established by one party or disproved by the other.
- The test of relevancy is whether an item of evidence will have any value, as
determined by logic and experience, in proving the proposition for which it is
offered, or whether it would reasonably and actually tend to prove or disprove
any matter if fact in issue, or corroborate other relevant evidence.
- The test is satisfied if there is a logical connection either directly or by inference
between the fact offered and the fact to be proved.
(3) Crucial in proving the chain of custody is the marking of the seized dangerous drugs
and related items immediately after they are seized, for it is the starting point in the
custodial link. The value of marking of the evidence is to separate the marked
evidence from the corpus of all other similar or related evidence from the time of
seizure until disposition, preventing switching or contaminating evidence. Failure to
mark imperils integrity of chain of custody.
- The records show that the buy bust ope did not observe the mandatory
procedures in RA 9165. Although Aninias supposedly marked the shabu with his
initials, he DID NOT do so in the presence of the accused or their
representatives and any representatives from the media and DOJ, or any
elected public official. In fact, the POs admitted to such. Instead, the media
were only around in the PDEA Regional headquarters.
- The certificate of inventory, although signed by a media rep and brgy official,
was nonetheless discredited by Aninias’ admission that only confident
informant and members of the team were present at the time of recovery.
- Another serious lapse was that no photographs were taken of the shabu upon
seizure. This is another means to confirm the chain of custody of the drugs.
- Moreover, no explanation was offered as to lapses in procedure committed by
the POs. They did not even recognize such lapses.
o Hence, the non-compliance for preserving the chain of custody left the
identity of the shabu ambiguous.

Fallo: Danny is ACQUITTED.