G.R. No. 240431 , July 7, 2020
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. MARLON BOB CARANIAGAN SANICO A.K.A. “MARLON BOB,” ACCUSED-APPELLANT.

FACTS

On September 30, 2009, a PDEA team conducted a buy-bust operation in Davao City based on information that accused-appellant Marlon Bob Caraniagan Sanico was selling marijuana. IO1 Rommel Adrian dela Peña acted as poseur-buyer and purchased three rolled newspapers containing dried marijuana fruiting tops for P150.00 from the appellant. Upon consummation of the sale, appellant jumped into the water and escaped. The seized items were marked by the officers at the scene, placed in an evidence pouch, and sealed. The team reported to the barangay hall and then to the PDEA office. The inventory was conducted only around 1:00 p.m. the following day in the presence of witnesses from the DOJ, media, and a barangay official. The items were later confirmed to be marijuana. Appellant was later arrested after being at-large, charged with violation of Section 5, Article II of R.A. 9165 (illegal sale of dangerous drugs), convicted by the RTC, and the conviction was affirmed by the Court of Appeals.

ISSUE

Whether the prosecution established the identity and integrity of the seized drugs with an unbroken chain of custody, in compliance with Section 21 of R.A. 9165.

RULING

No. The Supreme Court reversed the CA decision and acquitted the accused-appellant. The Court found that the apprehending officers did not comply with the mandatory requirements of Section 21 of R.A. 9165 and its Implementing Rules and Regulations. The physical inventory and photographing of the seized items were not conducted immediately after seizure and confiscation but only on the following day. This delay was not justified by any exceptional circumstances, and the prosecution failed to provide any justifiable ground for the non-compliance. The Court emphasized that strict adherence to the chain of custody procedure is required, especially in cases involving miniscule amounts of drugs, to remove doubts about the identity and integrity of the corpus delicti. Since the integrity and evidentiary value of the seized items were not preserved, appellant’s guilt was not proven beyond reasonable doubt.