G.R. No. 254412 . July 06, 2022.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. JOEL FANDIALAN Y BERNALDEZ, ACCUSED-APPELLANT.

FACTS

Accused-appellant Joel Fandialan was charged with illegal sale and possession of dangerous drugs. The prosecution alleged that a buy-bust operation was conducted on November 10, 2015, in Bay, Laguna. PO1 Joemel Lubrin acted as poseur-buyer and claimed that after the transaction, he apprehended Fandialan and recovered the marked money. A subsequent search allegedly yielded a “Mentos” candy container with three more sachets of suspected shabu. The police conducted an inventory and marking at the place of arrest in the presence of a media representative.
The defense presented a starkly different version. Fandialan testified that he was merely smoking in his yard when two men forcibly entered, assaulted him, and handcuffed him. He denied any drug transaction, claiming the evidence was planted. He stated that the inventory was a hurried process, with someone taking a picture using a mobile phone and declaring it sufficient. The Regional Trial Court convicted Fandialan, a decision affirmed by the Court of Appeals.

ISSUE

Whether the prosecution successfully established the identity and integrity of the seized dangerous drugs, constituting the corpus delicti, by proving an unbroken chain of custody in compliance with Section 21 of Republic Act No. 9165 .

RULING

The Supreme Court REVERSED the conviction and ACQUITTED accused-appellant. The prosecution failed to prove an unbroken chain of custody, compromising the identity and integrity of the corpus delicti. The Court emphasized that in drug cases, the State must account for each link in the chain: seizure, marking, turnover to the investigating officer, turnover to the forensic chemist, and submission to the court.
Critical gaps were found in the stipulated testimony of Forensic Chemist Police Inspector Annalee R. Palomo. The stipulation only covered her qualifications and the fact that she examined the items and found them positive for methamphetamine hydrochloride. It glaringly omitted the crucial procedure of how she received, handled, and stored the specimens for examination, and how she disposed of them afterward. This created a significant break in the chain after the items left police custody and before their presentation in court. The Court cited People v. Baltazar, where an acquittal was warranted due to similar omissions regarding post-examination custody. The presumption of regularity in police duty cannot prevail over the prosecution’s fundamental failure to establish the integrity of the evidence. Any reasonable doubt emanating from broken procedural links must be resolved in favor of the accused. Consequently, the guilt of the accused-appellant was not proven beyond reasonable doubt.