G.R. No. 198450, January 11, 2016
People of the Philippines, Plaintiff-Appellee, vs. Fernando Ranche Havana a.k.a. Fernando Ranche Abana, Accused-Appellant.

FACTS

Accused-appellant Fernando Ranche Havana was charged with illegal sale of dangerous drugs under Section 5, Article II of Republic Act No. 9165. The prosecution alleged that on November 4, 2005, a buy-bust operation was conducted in Cebu City where a civilian informant, acting as poseur-buyer, purchased a plastic sachet containing 0.03 gram of shabu from the appellant using marked money. The back-up police officers witnessed the transaction and subsequently arrested the appellant, recovering the marked money. The seized item was marked, submitted for laboratory examination, and tested positive for methylamphetamine hydrochloride.
The appellant denied the accusation, claiming he was merely eating at home when police officers barged in and arrested him, alleging a case of mistaken identity. The Regional Trial Court found him guilty and sentenced him to life imprisonment and a fine, a decision affirmed by the Court of Appeals. The appellant elevated the case to the Supreme Court, contending the prosecution failed to prove his guilt beyond reasonable doubt.

ISSUE

Whether the prosecution successfully established the identity and integrity of the seized dangerous drug, thereby proving the appellant’s guilt for illegal sale beyond reasonable doubt.

RULING

The Supreme Court acquitted the accused-appellant. The Court emphasized that in prosecutions for illegal sale of dangerous drugs, the identity of the drug must be established with moral certainty, and the chain of custody rule under Section 21 of RA 9165 is crucial to ensure the integrity of the evidence. The Court found that the apprehending officers committed unjustified deviations from the prescribed procedure.
The prosecution failed to present the civilian informant who acted as the poseur-buyer and who had initial custody of the seized drug. This created a significant gap in the chain of custody. Furthermore, the required witnesses during the physical inventory and photographing of the seized item—a representative from the media, the Department of Justice, and any elected public official—were absent. The prosecution offered no justifiable ground for this non-compliance. The police also failed to immediately conduct a physical inventory at the place of seizure or the police station, as required. These lapses, taken together, compromised the integrity and evidentiary value of the seized drug. Consequently, the prosecution failed to overcome the presumption of innocence.