G.R. No. 241950 April 10, 2019
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. ARCADIO MALABANAN y PERALTA and NORMAN QUITA y QUIBIDO, Accused-Appellants

FACTS

Accused-appellants Arcadio Malabanan and Norman Quita were charged with the illegal sale of dangerous drugs under Section 5 of Republic Act No. 9165. The prosecution alleged that on February 25, 2014, a buy-bust operation was conducted based on a tip from a confidential informant. PO1 Alvin Santos acted as poseur-buyer and purchased a sachet of shabu from the appellants inside a co-accused’s house. Upon consummation of the sale, the arrest was effected, and additional sachets were recovered. The seized items were marked at the scene, and the appellants were brought to the barangay hall for inventory and blotter recording before being taken to the police station.
The defense presented a starkly different version, claiming the appellants were victims of a frame-up. Quita alleged he was forcibly taken while helping a neighbor, and Malabanan claimed he was accosted on his way to go fishing. Both denied any participation in a drug transaction and asserted they were shown the drugs only after their arrest at the barangay hall.

ISSUE

Whether the prosecution established the guilt of the accused-appellants beyond reasonable doubt for the illegal sale of dangerous drugs, particularly in preserving the integrity and evidentiary value of the seized items through an unbroken chain of custody.

RULING

The Supreme Court ACQUITTED the accused-appellants. The Court reversed the rulings of the lower courts, finding a fatal breach in the chain of custody procedure under Section 21 of R.A. No. 9165, which compromised the identity and integrity of the seized drugs. The legal logic centered on the mandatory witness requirement during the physical inventory and photographing of seized items. The law requires the presence of an elected public official, a representative from the Department of Justice (DOJ), and a media representative.
The record showed that during the inventory at the barangay hall, only the head of the barangay tanod was present—who is not an elected official. The DOJ representative was called only after the inventory had been completed, and there was no showing that a media representative was ever present. This constituted not merely a deviation but a total absence of the required witnesses. The prosecution failed to offer any justifiable ground for this non-compliance. The police did not demonstrate earnest efforts to secure the witnesses’ presence beforehand, as there was no evidence that the appellants were a flight risk requiring immediate action without prior coordination. The unexplained breach created reasonable doubt on whether the drugs presented in court were the same ones allegedly seized from the appellants. Consequently, the integrity of the corpus delicti was not preserved, warranting acquittal.