G.R. No. 241836 . November 11, 2021
DANILO BELGA Y BRIZUELA, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

On March 1, 2014, two Informations were filed against Danilo Belga y Brizuela (petitioner) for violations of Sections 11 (Possession of Dangerous Drugs) and 12 (Possession of Drug Paraphernalia), Article II of R.A. 9165, as amended. The charges stemmed from a search conducted at his residence in Bacacay, Albay, at around 5:30 a.m. on February 28, 2014. During the search, police officers recovered three heat-sealed plastic sachets containing white crystalline substance (suspected shabu) and various drug paraphernalia. The prosecution presented witnesses, including the seizing officer (PO2 Alex Lucañas), arresting officer (Francis Ryle Camarce), team leader (PSI Luke Ventura), forensic chemist (PSI Wilfredo Pabustan), evidence custodian (PO2 Zarlyn Latoza), and barangay officials (Kagawad Renato Bertillo and Norma Cardiño), who testified on the briefing, execution of the search warrant, inventory conducted in the presence of required witnesses, and the positive laboratory result for methamphetamine hydrochloride. The defense presented petitioner, who denied the charges, claiming he was awakened by men who kicked his door, entered his house, forced him to lie down, and kicked him when he asked what they were looking for. The Regional Trial Court (RTC) convicted petitioner. The Court of Appeals (CA) affirmed the RTC’s decision.

ISSUE

Whether the Court of Appeals erred in affirming petitioner’s conviction for violations of Sections 11 and 12 of R.A. 9165.

RULING

The Supreme Court GRANTED the petition. The Court REVERSED and SET ASIDE the Decision and Resolution of the Court of Appeals and ACQUITTED petitioner Danilo Belga y Brizuela on reasonable doubt. The prosecution failed to establish an unbroken chain of custody of the seized items, which is crucial in proving the identity and integrity of the corpus delicti in drugs cases. Specifically, the prosecution did not present the testimony of PO2 Marlon Belleza, the officer who received the seized items from the seizing officer (PO2 Lucañas) and who delivered them to the crime laboratory. This gap in the chain of custody—between the seizing officer and the forensic chemist—was not justified and remained unexplained, creating reasonable doubt as to whether the items presented in court were the same ones seized from petitioner. The Court emphasized that every link in the chain must be accounted for, and the unjustified absence of a witness involved in the custody underscores the failure to prove guilt beyond reasonable doubt.