G.R. No. 249412 , March 15, 2021
People of the Philippines, Plaintiff-Appellee, vs. Gregorio Villalon, Jr. y Pabuaya alias “Jun-Jun,” Accused-Appellant.

FACTS

This case stemmed from three Informations charging accused-appellant Gregorio Villalon, Jr. with Illegal Sale and Possession of Dangerous Drugs and Illegal Possession of Drug Paraphernalia under Republic Act No. 9165 . The prosecution alleged that on September 6, 2015, a buy-bust operation was conducted based on confidential information. PO2 Alex J. Mahinay, as poseur-buyer, bought a plastic sachet of shabu from accused-appellant for PHP 1,500.00. Upon arrest, the marked money, three more plastic sachets of shabu, two lighters, and an improvised tube tooter were recovered from him. The seized items were marked, inventoried, and photographed at the police station in the presence of accused-appellant, an elected official, a media representative, and a DOJ representative. The items were then brought to the crime laboratory, where they tested positive for methamphetamine hydrochloride. The defense claimed accused-appellant was arbitrarily arrested while buying softdrinks and that the evidence was planted. The Regional Trial Court found accused-appellant guilty, a ruling affirmed by the Court of Appeals.

ISSUE

Whether or not accused-appellant is guilty beyond reasonable doubt of the crimes charged, particularly considering the chain of custody of the seized items.

RULING

The Supreme Court ACQUITTED accused-appellant. The Court found that while the prosecution established the first three links in the chain of custody (seizure and marking, turnover to investigating officer, and turnover to forensic chemist), it failed to establish the crucial fourth link: the turnover and submission of the illegal drug from the forensic chemist to the court. During trial, the prosecution and defense stipulated that the forensic chemist, P/SInsp. Alvin Raymundo Pascual, would testify that he conducted the examination and turned over the specimens to the evidence custodian, PO3 Ariel Magbanua. However, there was no stipulation or evidence presented to show that PO3 Magbanua, or any other officer, took the witness stand to testify on how the items were stored, preserved, and eventually presented in court. This failure to account for the final link in the chain of custody compromised the integrity and evidentiary value of the seized items, creating reasonable doubt as to whether the substances presented in court were the same ones confiscated from accused-appellant. Consequently, his guilt was not proven beyond reasonable doubt.