G.R. No. 250610 , July 10, 2023
People of the Philippines, Plaintiff-Appellee, vs. Francis Valencia y Lorenzo and Ryan Antipuesto, Accused-Appellants.

FACTS

Accused-appellants Francis Valencia and Ryan Antipuesto were charged with illegal sale of dangerous drugs under Section 5 of Republic Act No. 9165 . The prosecution’s evidence established that based on reports of Antipuesto’s drug trade, a buy-bust operation was arranged for January 16, 2016. Police Officer I Crisanto Panggoy acted as the poseur-buyer. At the meeting point, Antipuesto arrived with Valencia. Valencia handed a heat-sealed plastic sachet containing white crystalline substance to Panggoy, who then handed the buy-bust money to Antipuesto. Antipuesto escaped but Valencia was apprehended. Panggoy marked the seized sachet with “FLV/RA-BB-01-16-16” at the scene. Due to heavy traffic, the inventory and photographing were conducted at the police station in the presence of the accused, a barangay chairperson, a media representative, and a DOJ prosecutor. Panggoy retained custody of the evidence until he delivered it to the crime laboratory. Police Officer III Michelle Cañete, the evidence custodian at the laboratory, received the sealed evidence envelope. She allowed Panggoy to alter the marking on the letter request from “FLV/RA-BB-01-16-2016” to “FLV/RA-BB-01-16-16” to match the marking on the sachet. She then resealed the envelope. The forensic examination confirmed the substance was methamphetamine hydrochloride (shabu). The defense presented a different version, claiming Valencia was arbitrarily arrested from his boarding house and that no buy-bust occurred. The Regional Trial Court convicted both accused, a decision affirmed by the Court of Appeals.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellants for illegal sale of dangerous drugs, particularly regarding the preservation of the identity and integrity of the corpus delicti.

RULING

The Supreme Court REVERSED the Court of Appeals’ Decision and ACQUITTED accused-appellants Francis Valencia y Lorenzo and Ryan Antipuesto. The Court found that the prosecution failed to establish an unbroken chain of custody of the seized drugs, which compromised the identity and integrity of the corpus delicti. A critical break in the chain occurred when PO3 Cañete, the evidence custodian at the crime laboratory, allowed the poseur-buyer, PO1 Panggoy, to alter the marking on the letter-request that accompanied the evidence from “FLV/RA-BB-01-16-2016” to “FLV/RA-BB-01-16-16.” This alteration was made while the evidence was supposedly in Cañete’s custody and before its transfer to the forensic chemist. The Court ruled that receipts or documents showing the chain of custody cannot be altered or modified while the specimen is in transit to the next custodian. Even a minimal change in the marking stated in these documents is fatal to the identity and integrity of the corpus delicti. This irregularity created doubt as to whether the item examined was the same one seized from the accused. The justifying circumstances for non-compliance with the chain of custody procedures under Section 21 of RA 9165 were not proven. Consequently, the accused-appellants’ guilt was not proven beyond reasonable doubt.