G.R. No. 233800. March 06, 2019.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. MINDA PANTALLANO, ACCUSED-APPELLANT.
FACTS
Accused-appellant Minda Pantallano was charged with Illegal Sale and Illegal Possession of dangerous drugs. Based on a tip, PDEA agents conducted a buy-bust operation in Iligan City. A poseur-buyer purchased a sachet of shabu from Pantallano inside her house. After the consummated sale, the arresting team entered, apprehended Pantallano, and recovered the buy-bust money and four more sachets of shabu from a table behind a curtain. The seized items were inventoried at the scene in the presence of a barangay official, photographed, and later subjected to laboratory examination, which confirmed the presence of methamphetamine hydrochloride. The Regional Trial Court convicted Pantallano, a ruling affirmed by the Court of Appeals.
Pantallano appealed to the Supreme Court, arguing the prosecution failed to establish the identity and integrity of the seized drugs. She specifically contended that the chain of custody was broken because the inventory and photography were not conducted immediately at the place of arrest but after moving to another location within her house compound. She also claimed the required witnesses under Section 21 of RA 9165 were not present during the seizure.
ISSUE
Whether the prosecution successfully established an unbroken chain of custody over the seized dangerous drugs, thereby proving the corpus delicti and Pantallano’s guilt beyond reasonable doubt.
RULING
The Supreme Court ACQUITTED Pantallano. The prosecution failed to prove an unbroken chain of custody, creating reasonable doubt on the integrity of the evidence. The Court emphasized that in drug cases, the identity of the illicit drug must be established with moral certainty, requiring strict compliance with the chain of custody procedure under Section 21, Article II of RA 9165. This procedure is designed to preserve the integrity and evidentiary value of the seized items.
The legal logic centers on the broken links in the chain. First, the inventory and photography were not conducted immediately at the precise place of seizure. The team moved the items to a different spot within the compound, a deviation not justified by any showing that immediate compliance was impossible or would jeopardize the operation. Second, while a barangay official was present, the prosecution did not establish that the required witnesses from the media and the Department of Justice were present or that their absence was justified. The Court reiterated that while strict compliance may be excused under justifiable grounds, the prosecution must positively explain these deviations. Here, the prosecution offered no such explanation, merely invoking a presumption of regularity in the officers’ duties. This presumption cannot prevail over the constitutional presumption of innocence and the prosecution’s affirmative duty to prove guilt. Consequently, the integrity of the corpus delicti was compromised, warranting acquittal.