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FIRST DIVISION PEOPLE v. LOUIE CATALAN Y DEDALA

This case has been cited 4 times or more.

	GR No. 189296 2015-03-11	PEOPLE v. RECTO ANGNGAO Y MAKAY BERSAMIN, J.
Should the State not definitively establish that the dangerous drugs presented in court were the very same substances actually recovered from the accused, the criminal prosecution for drug pushing should fail because the guilt of the accused was not established beyond reasonable doubt.[14] According to People v. Catalan,[15] the Prosecution does not comply with the indispensable requirement of proving the violation of Section 5 of Republic Act No. 9165 if the dangerous drugs are missing, or if there are substantial gaps in the chain of custody of the seized dangerous drugs that raise doubts about the authenticity of the evidence presented in court. Indeed, the non-presentation of the dangerous drugs that constitute the corpus delicti would render the conviction unfounded.
	GR No. 212196 2015-01-12	PEOPLE v. RAMIL DORIA DAHIL MENDOZA, J.
The presentation of the dangerous drugs as evidence in court is material if not indispensable in every prosecution for the illegal sale and possession of dangerous drugs. As such, the identity of the dangerous drugs should be established beyond doubt by showing that the items offered in court were the same substances bought during the buy-bust operation. This rigorous requirement, known under R.A. No. 9165 as the chain of custody, performs the function of ensuring that unnecessary doubts concerning the identity of the evidence are removed.[23] In People v. Catalan,[24] the Court said: To discharge its duty of establishing the guilt of the accused beyond reasonable doubt, therefore, the Prosecution must prove the corpus delicti. That proof is vital to a judgment of conviction. On the other hand, the Prosecution does not comply with the indispensable requirement of proving the violation of Section 5 of Republic Act No. 9165 when the dangerous drugs are missing but also when there are substantial gaps in the chain of custody of the seized dangerous drugs that raise doubts about the authenticity of the evidence presented in court.
	GR No. 192432 2014-06-23	PEOPLE v. LARRY MENDOZA Y ESTRADA BERSAMIN, J.
The presentation of the dangerous drugs as evidence in court is material if not indispensable in every prosecution for the illegal sale of dangerous drugs. As such, the identity of the dangerous drugs should be established beyond doubt by showing that the dangerous drugs offered in court were the same substances bought during the buy-bust operation. This rigorous requirement, known under RA No. 9165 as the chain of custody, performs the function of ensuring that unnecessary doubts concerning the identity of the evidence are removed.[12] As the Court has expounded in People v. Catalan,[13] the dangerous drugs are themselves the corpus delicti; hence:To discharge its duty of establishing the guilt of the accused beyond reasonable doubt, therefore, the Prosecution must prove the corpus delicti. That proof is vital to a judgment of conviction. On the other hand, the Prosecution does not comply with the indispensable requirement of proving the violation of Section 5 of Republic Act No. 9165 when the dangerous drugs are missing but also when there are substantial gaps in the chain of custody of the seized dangerous drugs that raise doubts about the authenticity of the evidence presented in court.[14]
	GR No. 199689 2014-03-12	PEOPLE v. HERMANOS CONSTANTINO LEONARDO-DE CASTRO, J.
Herein, the prosecution is completely silent as to why PO3 Domingo, the poseur-buyer, despite having immediate custody of the two plastic sachets of shabu purchased from Constantino, failed to immediately mark the seized drugs before turning over the custody of the same to another police officer. This lapse in procedure opened the door for confusion and doubt as to the identity of the drugs actually seized from Constantino during the buy-bust and the ones presented before the trial court, especially considering that three different people, during the interval, supposedly received and marked the same. To clarify the matter, the prosecution could have presented as witness either SPO2 Tamang or SPO2 Taguiam to directly validate the marking in court, but unfortunately, the prosecution chose to dispense with the testimonies of both officers. This omission diminished the importance of the markings as the reference point for the subsequent handling of the evidence. As a consequence, an objective person could now justifiably suspect the shabu ultimately presented as evidence in court to be planted or contaminated.[30]