DEFENSE SYNOPSIS FOR THE ACCUSED:

This is a Criminal Action filed by the People of the Philippines against the
Accused, Jenny De Castro y Reyes, for the alleged violation of Section 5 and
Section 11 of RA 9165, otherwise known as Comprehensive Dangerous Drugs
Act of 2002.
As advocates for the Accused, we submit this counter-affidavit stating therein that
she is not the criminal who should suffer the harsh penalties meted out under the
said law, but rather the victim of a ruthless, well-orchestrated extortion operation
conducted by SPO1 Arpon and PO1 Pili, in the guise of a buy-bust operation.
The Accused Was a Victim of Extortion of Money
We shall present testimonial witnesses who will prove that on the night of January
12, 2012, the Accused was not standing along Moriones St. in Tondo, Manila,
selling illegal drugs. We will show that she was only there to send off a co-worker,
when she was accosted by SPO1 Arpon and PO1 Pili, who then by coercion,
attempted to extort money from the Accused by making an accusation against her,
to operate to her prejudice.
The Arresting Officers Broke the Chain of Custody

We shall also present documentary evidence to show that the said officers failed to
comply with the procedural requirements of the observance of the chain of custody
in handling and preserving the integrity of the drugs they allegedly seized from the
Accused, while in pari delicto, without justifiable grounds.
The law presumes that an accused in a criminal prosecution is innocent until
the contrary is proved. The presumption of innocence of an accused in a criminal
case is a basic constitutional principle, fleshed out by procedural rules which place
on the prosecution the burden of proving that an accused is guilty of the offense
charged by proof beyond reasonable doubt.
We believe that in this case of the People against the Accused, the People
have failed to provide the requisite burden of evidence to warrant the establishment
of her guilt of the violations she has been charged with.