G.R. No. 129376 ; May 29, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANGELITO TAN Y NUBLA, accused-appellant.

FACTS

The prosecution alleged that based on a tip, a buy-bust operation was conducted against a certain “Lito.” Posing as a buyer, SPO1 Liberato Abalos met accused-appellant Angelito Tan at a Quezon City street corner. Tan handed over a plastic bag containing five sachets of a substance later confirmed as methamphetamine hydrochloride (shabu). Upon receiving the marked money, Tan attempted to flee but was apprehended. Forensic tests confirmed the substance was shabu and that Tan’s hands tested positive for ultraviolet powder from the marked bills.
Accused-appellant presented a starkly different narrative. He claimed he was forcibly taken from his condominium by men alleging his nephew’s car was carnapped. He was detained and told he would be released for a ₱1 million ransom. Later, under the pretext of getting money from his house, an officer lent him marked bills, which were then snatched back, explaining the powder on his hands. He asserted he was framed and presented alibi evidence and corroborating witnesses.

ISSUE

The core issue is whether the prosecution successfully proved the guilt of the accused-appellant for the illegal sale of dangerous drugs beyond reasonable doubt.

RULING

The Supreme Court ACQUITTED accused-appellant Angelito Tan. The ruling hinged on the prosecution’s failure to establish the integrity and identity of the seized drugs, a crucial element of the crime. The Court found a broken chain of custody. The poseur-buyer, SPO1 Abalos, testified that he marked the seized plastic bag only upon reaching the police station, not immediately at the place of arrest. There was no evidence showing who had possession of the drugs from the moment of arrest until they were marked. Furthermore, the officer who supposedly delivered the evidence to the NBI for examination was not presented to testify, creating a significant gap. This failure to account for the evidence’s movement and safekeeping raises doubt about whether the substance presented in court was the same one allegedly seized from Tan. In drug cases, the State must prove an unbroken chain of custody to negate possibilities of switching, planting, or contamination. The prosecution’s non-compliance with this strict requirement, coupled with the inconsistencies in the police officers’ testimonies regarding the operation’s details, created reasonable doubt. The Court emphasized that while the fight against illegal drugs is paramount, it must be pursued within the bounds of law, and the constitutional presumption of innocence prevails when the evidence is wanting.