G.R. No. 225747 . December 05, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. JEFFERSON MEDINA Y CRUZ, ACCUSED-APPELLANT.

FACTS

This case stemmed from a buy-bust operation conducted on April 26, 2010, where accused-appellant Jefferson Medina was arrested for allegedly selling one plastic sachet of white crystalline substance. The prosecution evidence showed that PO3 Honorato Quintero, Jr. marked the seized item at the place of arrest. The team then brought Medina and the item to the police station, where PO3 Ariosto B. Rana conducted an inventory and photography in the presence of a media representative, Maeng Santos. The item was later examined and confirmed to be 0.05 gram of shabu. Medina denied the accusation, claiming he was unlawfully arrested at his home by men looking for another person.
The Regional Trial Court found Medina guilty beyond reasonable doubt of Illegal Sale of Dangerous Drugs under Section 5, Article II of Republic Act No. 9165 , and sentenced him to life imprisonment and a fine. The Court of Appeals affirmed this ruling, holding that all elements of the crime were established and the chain of custody was preserved. Medina appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming Medina’s conviction despite alleged breaches in the chain of custody of the seized dangerous drugs.

RULING

The Supreme Court granted the appeal and acquitted Medina. The Court emphasized that in drug cases, the identity of the dangerous drug must be established with moral certainty, requiring strict compliance with the chain of custody procedure under Section 21, Article II of RA 9165. This procedure mandates that the inventory and photography of seized items be conducted immediately after seizure and confiscation in the presence of the accused or his representative, and required witnesses, including a representative from the media AND the Department of Justice, and any elected public official.
The Court found a fatal breach in the chain of custody. The inventory was conducted only in the presence of a media representative, Santos. There was no representative from the DOJ, nor any elected public official present during the inventory as required by law at the time. The prosecution offered no justification for this non-compliance. The absence of these indispensable witnesses compromised the integrity of the seized evidence, as their presence is precisely intended to insulate the proceedings from any suspicion of switching, planting, or contamination. Consequently, the prosecution failed to prove the corpus delicti of the crime beyond reasonable doubt. The presumption of regularity in the performance of official duty cannot prevail over the stronger presumption of innocence in favor of the accused when there is a clear lapse in the prescribed procedure. Medina’s acquittal was thus ordered.