GR 185460; (July, 2012) (Digest)
G.R. No. 185460; July 25, 2012
EDWIN FAJARDO and REYNALDO CORALDE, Petitioners, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
Acting on a tip regarding a pot session, police officers proceeded to a house in Quezon City on December 21, 2002. Upon arrival, they observed the petitioners, Edwin Fajardo and Reynaldo Coralde, along with another individual, Gerry Malabanan, through a slightly open door. The officers testified they saw the individuals in possession of drug paraphernalia: Fajardo with an aluminum foil and Coralde with a lighter and a tooter. The officers introduced themselves, entered, and confiscated various items, including plastic sachets, aluminum foil, lighters, and a glass pipe. The petitioners presented a different account, claiming they were merely visiting—Fajardo to retrieve a pawned cellphone and Malabanan to accompany Coralde’s wife to the hospital—when police suddenly barged in without announcement, causing them to flee out of surprise and fear.
ISSUE
Whether the prosecution proved the guilt of the petitioners for illegal possession of dangerous drugs and drug paraphernalia beyond reasonable doubt.
RULING
No. The Supreme Court reversed the convictions and acquitted the petitioners. The Court emphasized that in prosecutions for illegal possession, the State must prove (a) the accused’s possession of the illicit item, (b) such possession was not authorized by law, and (c) the accused freely and consciously possessed the item. Crucially, the identity and integrity of the seized evidence must be established with moral certainty through an unbroken chain of custody. Here, the prosecution failed on this essential point. The police officers provided inconsistent testimonies regarding who exactly possessed which specific items upon entry. More fatally, the Chemistry Report revealed that several confiscated items, including the lighters and scissor allegedly seized from the petitioners, were never even qualitatively examined for dangerous drugs. The report only confirmed the presence of shabu in some plastic sachets, but the link between these positive specimens and the petitioners was not conclusively proven due to the procedural lapses and evidentiary gaps. The doubt created by the failure to examine key pieces of evidence and the inconsistencies in the police narrative warranted acquittal. The presumption of innocence must prevail when the evidence does not establish guilt beyond reasonable doubt.