The law presumes that an accused in a

criminal prosecution is innocent until the

contrary is proved. This basic constitutional
principle is fleshed out by procedural rules
which place on the prosecution the burden
of proving that an accused is guilty of the
offence
charged
by
proof
beyond
reasonable doubt.

People v. Ulat
G.R. No. 180504. 5 October 2011

The law prescribes specific procedures on

the seizure and custody of drugs,
independently of the general procedures
geared to ensure that the rights of people
under criminal investigation and of the
accused facing a criminal charge are
safeguarded.

According to the prosecution, a confidential

informant relayed information regard the
illegal drug trade activity of an alias
Pudong. The police conducted a buy-bust
operation if indeed there was illegal drug
trade. The operation proved successful and
in the polices custody was alias Pudong.
Then, Pudong was brought to the Makati
DEU
for
proper
investigation.
The
investigator also prepared for a request for
laboratory examination of the specimen
purported
to
be
methamphetamine
hydrochloride, which was obtained from
Pudong. A sworn statement was also made
in connection with the buy-bust operation.

In this case, however, the prosecution failed

to demonstrate with moral certainty that
the identity and integrity of the prohibited
drug, which constitutes the corpus delicti,
had been duly preserved.
The records reveal that the prosecution did
not establish the exact location where the
confiscated illegal drug was marked and the
identity of the person who marked it
because of contradicting testimonies of the
prosecutions witnesses. The conspicuous
variance in the testimonies for the
prosecution casts serious doubt on the
arresting teams due care in the custody of
the confiscated illegal drug.
Taking into consideration all the conflicting
accounts of the prosecutions witnesses,
the Supreme Court held that any
reasonable mind would entertain grave
reservations as to the identity and integrity
of the confiscated sachet of shabu
submitted for laboratory examination.
In Zaragga v. People, the Supreme Court
held that the material inconsistencies with
regard to when and where the markings on
the shabu were made and the lack of
inventory on the seized drugs created
reasonable doubt as to the identity of the
corpus delicti. Thus, the accused were
acquitted due to the prosecutions failure to
indubitably show the identity of the shabu.
In this case, the acquittal of Ulat is proper
for the failure of the prosecution to prove
his guilt beyond reasonable doubt.

Facts:
Edwin Ulat (Ulat) was charged in an
information with violation of Section 5,
Article II of RA 9165. Ulat pleaded not guilty
when he was arraigned.

On the other hand, the defence narrated

that Ulat was at home watching television
when he saw five to seven men in front of
their door whom he thought were looking
for someone. He approached them and
asked who they were looking for. A gun was
poked at him and he was told to go with
them to the barangay hall. He was asked if
he knew a certain Sandy, which he denied.
He was brought to the barangay hall and
then to the Criminal Investigation Division.
After due proceedings, the trial court
convicted Ulat of the crime charged against
him. On review, the Court of Appeals
upheld the ruling of the trial court. Hence,
Ulat appealed before the Supreme Court.
Issue:
Whether the conviction was proper despite
the fact that the witnesses for the
prosecution allegedly presented conflicting
testimonies on material points regarding
the chain of custody of the illegal drug
taken from Ulat.
Ruling:
No. The conviction was not proper.