GR 227336; (February, 2018) (Digest)
G.R. No. 227336 February 26, 2018
ROMMEL RAMOS y LODRONIO, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
Petitioner Rommel Ramos was charged with illegal possession of dangerous drugs under Section 11, Article II of R.A. No. 9165. The prosecution alleged that during a buy-bust operation targeting his co-accused Rodrigo Bautista, police officers recovered two plastic sachets of marijuana from Ramos’s possession. The officers marked the seized items at the scene, turned them over to the investigating officer at the station, who then delivered them to the crime laboratory for examination, which yielded positive results for marijuana. The Regional Trial Court convicted Ramos, a ruling affirmed by the Court of Appeals.
The defense presented a starkly different version, claiming the arrest was a frame-up. Ramos testified that he was forcibly taken from a street, brought to Bautista’s house, and later coerced at the police station to identify other drug dealers. He alleged that the police demanded money from Bautista’s mother for his release. The defense argued that the prosecution failed to establish an unbroken chain of custody over the seized drugs.
ISSUE
Whether the prosecution successfully proved the guilt of the petitioner for illegal possession of dangerous drugs beyond reasonable doubt, particularly in establishing the integrity and identity of the corpus delicti through an unbroken chain of custody.
RULING
The Supreme Court ACQUITTED petitioner Rommel Ramos. The Court emphasized that in prosecutions for illegal possession of dangerous drugs, the identity of the prohibited drug must be established with moral certainty. This requires the prosecution to account for each link in the chain of custody—from seizure, marking, inventory, to laboratory examination—in a manner that rules out tampering, alteration, or substitution.
The Court found fatal gaps in the chain of custody. Crucially, the prosecution failed to present the investigating officer, PO3 Lauro P. dela Cruz, who received the seized items from the arresting officers and personally delivered them to the forensic chemist. His testimony was indispensable to establish the crucial link between the police station and the laboratory. His absence created a significant break in the chain, leaving a doubt as to whether the items examined were the same ones seized from Ramos. The Court also noted the failure of the police to strictly comply with the witness requirements for the inventory under Section 21 of R.A. No. 9165. While minor procedural lapses may be excused, the unexplained absence of a key custodian like PO3 dela Cruz is a fatal procedural gap. Consequently, the integrity and identity of the corpus delicti were compromised, warranting acquittal on reasonable doubt.