G.R. No. 238117 , February 4, 2019
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. EDWIN ALCONDE y MADLA and JULIUS QUERQUELA y REBACA, Accused-Appellants.

FACTS

Accused-appellants were charged with Illegal Sale and Illegal Possession of Dangerous Drugs. The prosecution alleged that based on information from a previously arrested individual, a buy-bust operation was arranged. During the operation, PO3 Agravante handed marked money to Querquela, and Alconde handed over two sachets of shabu. Upon arrest, a body search of Alconde yielded another sachet containing marijuana. The seized items were photographed at the scene with the accused present. The marking and inventory, however, were conducted later at the police station in the presence of the accused and a Barangay Captain. The defense claimed they were victims of a frame-up, with Alconde asserting he was forced to hold a sachet for a photograph at the station.
The Regional Trial Court convicted accused-appellants, a ruling affirmed by the Court of Appeals. The CA held that all elements of the crimes were established and that the chain of custody was substantially complied with, preserving the integrity of the seized drugs.

ISSUE

Whether the Court of Appeals correctly upheld the conviction by finding proper compliance with the chain of custody rule under Section 21, Article II of Republic Act No. 9165 .

RULING

The Supreme Court reversed the convictions and acquitted accused-appellants. The Court emphasized that in drug cases, the identity and integrity of the corpus delicti must be established with moral certainty through an unbroken chain of custody. Section 21 requires that the physical inventory and photography of seized items be conducted immediately after seizure and confiscation, in the presence of the accused and specific witnesses: a representative from the media, the Department of Justice, and any elected public official.
Here, the prosecution admitted that the inventory and photography were not done immediately at the place of arrest. While the items were photographed at the scene, the required inventory was only conducted at the police station. Crucially, the prosecution failed to secure the presence of the mandatory witnesses—a media representative and a DOJ official—during the inventory. Only a Barangay Captain was present. The prosecution offered no justifiable reason for this procedural lapse. The law mandates strict compliance, and the absence of the required witnesses, without a credible explanation, fatally breaks the chain of custody. Consequently, the integrity and evidentiary value of the seized items were compromised, warranting acquittal based on reasonable doubt.