G.R. No. 260990. June 21, 2023.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ANTHONY DAVID Y MATAWARAN @ “ANTO”, ACCUSED-APPELLANT.

FACTS

The case stemmed from two Informations charging accused-appellant Anthony David y Matawaran with Illegal Sale and Illegal Possession of Dangerous Drugs under Sections 5 and 11, Article II of Republic Act No. 9165. The charges arose from a buy-bust operation on August 16, 2015, in Samal, Bataan. The prosecution’s version states that a confidential informant reported accused-appellant’s drug activities. A buy-bust team was formed, with PO1 Joey Santos as the poseur-buyer and SPO1 Rommel Buduan as backup. PO1 Santos used a marked ₱500 bill to buy one sachet of suspected shabu from accused-appellant. Upon arrest and search, another sachet was recovered from accused-appellant. The seized items were marked “JCS-1” (sale) and “JCS-2” (possession). An inventory was conducted at the police station in the presence of representatives from the DOJ, media, and a barangay official. The items tested positive for methamphetamine hydrochloride. The defense version claimed accused-appellant was arbitrarily arrested while driving his tricycle, and the drugs were planted. The Regional Trial Court found accused-appellant guilty, which the Court of Appeals affirmed. Accused-appellant appealed to the Supreme Court.

ISSUE

Whether accused-appellant is guilty beyond reasonable doubt of Illegal Sale and Illegal Possession of Dangerous Drugs.

RULING

The Supreme Court granted the appeal and acquitted accused-appellant. The Court found that the prosecution failed to establish an unbroken chain of custody of the seized drugs, thereby failing to prove the integrity and identity of the corpus delicti beyond reasonable doubt. Specifically, the apprehending officers did not comply with the mandatory witness requirement under Section 21 of RA 9165 during the physical inventory and photographing of the seized items. The required witnesses—an elected public official, a representative from the Department of Justice, and a representative from the media—were not present at the time and place of seizure and apprehension. Their presence only at the police station, without any justifiable reason for not conducting the inventory at the place of arrest, constituted a substantial gap in the chain of custody. The presumption of regularity in the performance of official duty could not apply due to these unjustified deviations from the statutory procedure. Consequently, the guilt of the accused was not proven to the required moral certainty.