G.R. No. 229053 , July 17, 2019
People of the Philippines, Plaintiff-Appellee vs. Jordan Casaclang Dela Cruz, Accused-Appellant

FACTS

Accused-appellant Jordan Casaclang Dela Cruz was charged with illegal sale and illegal possession of marijuana following a buy-bust operation on July 10, 2012. The prosecution alleged that PO1 Denver Santillan, acting as a poseur-buyer, purchased two plastic sachets from Dela Cruz and recovered two more sachets during a subsequent body search. The seized items were marked by PO1 Santillan at the scene. He then retained custody of the drugs until they were turned over to the crime laboratory for examination, which confirmed the substance was marijuana. The Regional Trial Court convicted Dela Cruz, a ruling affirmed by the Court of Appeals.
Dela Cruz denied the accusations, claiming he was forcibly taken by unidentified men from his school and framed. On appeal before the Supreme Court, he argued that the prosecution failed to establish an unbroken chain of custody over the seized drugs, specifically pointing to the lack of testimony from the investigating officer who received the evidence from the arresting officer and the absence of witnesses required by law during the inventory and photographing of the seized items.

ISSUE

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

RULING

No. The Supreme Court reversed the conviction and acquitted Dela Cruz due to the prosecution’s unjustified noncompliance with the chain of custody requirements under Section 21 of Republic Act No. 9165 . The law mandates that immediately after seizure, the inventory and photographing of the drugs must be conducted 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 offer any justifiable reason for the absence of these required witnesses during the inventory. This procedural lapse was compounded by a significant gap in the chain: while PO1 Santillan claimed he personally brought the drugs to the crime laboratory, the forensic chemist testified she received them from an investigating officer, PO3 Vinluan. This inconsistency created doubt about who handled the evidence between the arrest and laboratory examination. The Court emphasized that unjustified deviations from the strict custody procedures negate the presumption of regularity accorded to police officers. Consequently, the identity and integrity of the corpus delicti were compromised, which is fatal to the prosecution’s case. The constitutional presumption of innocence therefore prevails, warranting acquittal.