G.R. No. 189843 ; March 20, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ZENAIDA SORIANO y USI and MYRNA SAMONTE y HIOLEN, Accused-Appellants.

FACTS

The prosecution’s case stemmed from a buy-bust operation on June 10, 2003, in San Rafael, Bulacan. A confidential informant reported that a certain “Zeny” was selling illegal drugs. A team was formed, with PO1 Carlito Bernardo as the poseur-buyer. The informant introduced Bernardo to Zenaida Soriano (Zeny) and Myrna Samonte. Upon agreement, Bernardo handed marked money to Soriano, who then passed it to Samonte. Soriano retrieved a plastic sachet of shabu from a matchbox and gave it to Bernardo, who then signaled the arrest. Upon arrest, the matchbox containing six more sachets was recovered from Soriano, while the marked money and another sachet were seized from Samonte. The items tested positive for methamphetamine hydrochloride.
The defense presented a starkly different version. Soriano testified that armed men forcibly entered her home, searched it without explanation, and then abducted her. She was brought to a vehicle where she saw Samonte, and they were taken to a hospital and then to the police camp. Both accused denied any involvement in drug transactions, claiming the evidence was fabricated and that they were victims of a frame-up. The trial court convicted them for illegal sale and possession of dangerous drugs, a decision affirmed by the Court of Appeals.

ISSUE

The core issue is whether the prosecution successfully proved the guilt of the accused-appellants for the crimes charged beyond reasonable doubt, particularly in light of alleged irregularities in the chain of custody of the seized drugs.

RULING

The Supreme Court acquitted the accused-appellants. The ruling hinged on the prosecution’s failure to establish an unbroken chain of custody, which is crucial in proving the identity and integrity of the seized drugs—the corpus delicti of the offenses. The Court emphasized that in drug cases, the State must account for each link in the chain: from seizure, to marking, to turnover for laboratory examination, to submission to the court. The buy-bust team committed significant deviations from the procedure mandated under Section 21 of Republic Act No. 9165 . PO1 Bernardo admitted that the inventory of the seized items was not conducted in the presence of the accused, any elected public official, a representative from the Department of Justice, or the media. No justifiable reason was provided for this non-compliance. The prosecution offered no explanation for these lapses, which compromised the integrity of the evidence. While strict compliance may not always be required, the prosecution must convincingly justify any deviation. Here, the failure to offer any explanation was fatal. The Court ruled that the integrity and evidentiary value of the seized items were therefore not preserved, creating reasonable doubt as to whether the items presented in court were the same ones allegedly seized from the appellants. Consequently, without the corpus delicti being proven with moral certainty, the conviction could not stand.