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 for the alleged sale of 0.02 grams of shabu to PO1 Renen Malonzo during a buy-bust operation in Caloocan City on November 30, 2007. The prosecution presented PO1 Malonzo and SPO2 Wilfredo Quillan, who testified that a pre-operation report was coordinated with the PDEA and that the accused handed over the drugs in exchange for marked money. The seized item was marked and later tested positive for methamphetamine hydrochloride.
The defense presented a different version, claiming Oliveros was arbitrarily arrested at a billiard hall and that the case was filed after he failed to produce a PhP10,000.00 bribe demand. The Regional Trial Court convicted Oliveros, a decision affirmed by the Court of Appeals. Oliveros appealed to the Supreme Court, arguing the prosecution failed to establish an unbroken chain of custody for the seized drugs.

ISSUE

Whether the prosecution successfully established the identity and integrity of the seized dangerous drug, preserving an unbroken chain of custody as required under Section 21 of R.A. No. 9165.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED accused-appellant Darren Oliveros. The Court emphasized that departures from the strict procedural safeguards for handling seized drugs under Section 21 of R.A. No. 9165 must be justified; otherwise, they severely compromise the integrity of the corpus delicti. In this case, the arresting officers committed significant lapses.
The buy-bust team failed to conduct a physical inventory and to photograph the seized drug in the presence of the insulating witnesses mandated by law—namely, a representative from the Department of Justice, the media, and an elected public official. These witnesses are crucial to prevent risks of tampering, substitution, or planting of evidence. Furthermore, the prosecution offered no justifiable reason for this non-compliance. The testimony also revealed that the forensic chemist received the request for examination and the specimen from an officer not part of the arresting team, creating another gap in the chain of custody. These unexcused procedural breaches created reasonable doubt regarding the identity and integrity of the evidence allegedly seized from the accused. Consequently, the prosecution failed to prove Oliveros’s guilt beyond reasonable doubt, necessitating his acquittal.