G.R. No. 218126 . July 10, 2019.
THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. DANILO GARCIA MIRANDA, Accused-Appellant.

FACTS

Accused-appellant Danilo Garcia Miranda was convicted by the Regional Trial Court for violations of Sections 5 (sale) and 11 (possession) of Republic Act No. 9165 . The prosecution evidence established that a buy-bust operation was conducted based on a tip. PO3 Fernan Acbang acted as poseur-buyer and purchased one plastic sachet of shabu from Miranda using marked money. Upon arrest, another sachet was recovered from Miranda’s pocket. The items were marked at the scene in the presence of a barangay tanod. The seized items tested positive for methamphetamine hydrochloride. Miranda denied the charges, claiming he was framed, alleging he was merely resting in his house when police officers forcibly entered and arrested him.
The Court of Appeals affirmed the conviction. On appeal to the Supreme Court, Miranda argued that the prosecution failed to establish an unbroken chain of custody of the seized drugs, particularly contesting the absence of required witnesses during the inventory and the lack of evidence on the handling of the items between seizure and laboratory examination.

ISSUE

Whether the prosecution successfully established the identity and integrity of the seized dangerous drugs, thereby proving the guilt of the accused beyond reasonable doubt.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED accused-appellant Danilo Garcia Miranda. The Court emphasized that in drug-related prosecutions, the identity of the corpus delicti must be established with moral certainty through an unbroken chain of custody. The procedure under Section 21 of RA 9165 requires the inventory and photographing of seized items to be conducted immediately after seizure and in the presence of the accused or his representative, a representative from the media, the Department of Justice, and any elected public official.
The prosecution failed to justify non-compliance with these witness requirements. Only a barangay tanod was present during the inventory. The prosecution did not offer any explanation for the absence of the other mandatory witnesses, nor did it demonstrate earnest efforts to secure their presence. This constituted a clear breach of the chain of custody rule. Furthermore, the prosecution’s evidence was insufficient to account for the movement and safekeeping of the seized items from the time they were marked at the scene until they were delivered to the crime laboratory. These gaps in the chain of custody created reasonable doubt as to whether the items presented in court were the same ones seized from the accused. Consequently, the integrity and identity of the corpus delicti were compromised, warranting acquittal.