G.R. No. 254320 . July 05, 2021.
Joe Anne Fernandez y Bueno, Petitioner, vs. People of the Philippines, Respondent.

FACTS

This case stemmed from three Informations filed before the Regional Trial Court (RTC) charging petitioner Joe Anne Fernandez y Bueno with Illegal Possession of Dangerous Drugs (Sec. 11, RA 9165), Illegal Possession of Drug Paraphernalia (Sec. 12), and Illegal Use of Dangerous Drugs (Sec. 15). The prosecution alleged that on October 30, 2015, police officers implemented a search warrant at petitioner’s residence in Cabangan, Zambales. Upon arrival, they saw petitioner handing a plastic sachet to another man who escaped. Petitioner ran but was apprehended. The search yielded four plastic sachets containing white crystalline substance and assorted drug paraphernalia. The police conducted marking, inventory, and photography at the crime scene in the presence of petitioner and barangay officials. The seized sachets were kept in the custody of PO2 Cacho in his locker until November 2, 2015, when they were turned over to the evidence custodian and subsequently to the forensic chemist, who confirmed the contents were methylamphetamine hydrochloride. The drug paraphernalia were not submitted for laboratory examination. Petitioner denied the charges, claiming the police planted evidence. The RTC convicted petitioner for Illegal Possession of Dangerous Drugs but acquitted him for Illegal Possession of Drug Paraphernalia (due to non-presentation of the paraphernalia as evidence) and dismissed the Illegal Use charge (as it is absorbed in Illegal Possession). The CA affirmed the RTC’s decision.

ISSUE

Whether or not petitioner is guilty beyond reasonable doubt of Illegal Possession of Dangerous Drugs.

RULING

No. The Supreme Court granted the petition and acquitted petitioner. The Court found that the prosecution failed to establish an unbroken chain of custody of the seized drugs, which is crucial in proving the corpus delicti. The apprehending team did not comply with the witness requirements under Section 21 of RA 9165, as the inventory was conducted only in the presence of barangay officials, without a representative from the media or the Department of Justice (DOJ). The prosecution did not offer any justifiable ground for this deviation. Furthermore, there was a gap in the chain of custody when PO2 Cacho kept the seized drugs in his personal locker from October 30 to November 2, 2015, without evidence showing how the integrity and evidentiary value of the items were preserved during this period. The prosecution also failed to present testimony from the forensic chemist on the handling and analysis of the specimens. These lapses collectively compromised the identity and integrity of the seized drugs, warranting acquittal on reasonable doubt.