G.R. No. 212202. July 30, 2019. PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. DARREN OLIVEROS Y CORPORAL, Accused-Appellant.
FACTS

Accused-appellant Darren Oliveros y Corporal was charged with violating Section 5 of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) for the alleged sale of 0.02 grams of shabu to a police poseur-buyer in Caloocan City on November 30, 2007. The prosecution evidence, primarily from PO1 Renen Malonzo, detailed a buy-bust operation where Oliveros was arrested after allegedly handing over a plastic sachet in exchange for marked money. The seized item was marked and later tested positive for methylamphetamine hydrochloride. The defense, however, presented a frame-up, alleging the arrest occurred at a billiard hall and that the case was filed after he failed to produce a demanded sum of money.
The Regional Trial Court convicted Oliveros, a decision affirmed by the Court of Appeals. On appeal to the Supreme Court, the core dispute centered on the integrity of the seized drug’s chain of custody.

ISSUE

Whether the prosecution successfully established the identity and integrity of the corpus delicti (the seized dangerous drug) through an unbroken chain of custody, thereby proving the guilt of the accused beyond reasonable doubt.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED accused-appellant Darren Oliveros. The Court ruled that the prosecution failed to prove an unbroken chain of custody due to unjustified deviations from the mandatory procedures under Section 21 of R.A. No. 9165. The arresting officers committed significant lapses: they failed to conduct an immediate physical inventory and to photograph the seized drugs in the presence of the accused or his representative, a representative from the Department of Justice, the media, and an elected public official, as expressly required by law.
Crucially, the prosecution offered no justifiable reason for this non-compliance. The law requires such stringent safeguards precisely to insulate the seizure from risks of tampering, substitution, or planting of evidence. The Court emphasized that while strict literal compliance may not always be possible, the prosecution must credibly explain any departure. Here, the absence of any justification, coupled with the minuscule quantity of drugs involved (0.02 grams), severely compromised the integrity of the evidence. These gaps in the chain of custody created reasonable doubt as to whether the item presented in court was the same one allegedly seized from the accused. Consequently, the identity of the corpus delicti was not established with moral certainty, warranting acquittal.