G.R. No. 173794; January 18, 2012
People of the Philippines, Plaintiff-Appellee, vs. Darwin Relato y Ajero, Accused-Appellant.

FACTS

Accused-appellant Darwin Relato y Ajero was convicted for violating Section 5 of Republic Act No. 9165 (illegal sale of dangerous drugs). The prosecution’s evidence showed that on August 29, 2002, a police team conducted a buy-bust operation in Barangay Aquino, Bulan, Sorsogon. A police asset acted as poseur-buyer and purchased two plastic sachets of suspected shabu from Relato for a marked ₱500.00 bill. Relato was apprehended, and the marked money was recovered from him. The poseur-buyer turned over the two sachets to PO3 Sonny Evasco. At the police station, SPO1 Elmer Masujer marked the sachets with his initials “EM.” Forensic examination confirmed the contents were methamphetamine hydrochloride weighing 0.0991 gram. Relato denied the charge, claiming he was framed. He testified that he and a companion, Pido Paredes, were on their way to a wake when police officers suddenly arrested him, handcuffed him, and confiscated his cellphone and personal money. He alleged that at the police station, SPO1 Masujer took two sachets from his own wallet, placed them on a table, and made Relato point to them for a photograph. The Regional Trial Court (RTC) convicted Relato and sentenced him to life imprisonment and a fine. The Court of Appeals (CA) affirmed the conviction.

ISSUE

Whether the prosecution established the guilt of the accused beyond reasonable doubt, particularly in complying with the chain of custody requirements under Section 21 of Republic Act No. 9165.

RULING

The Supreme Court REVERSED the decision of the Court of Appeals and ACQUITTED Darwin Relato y Ajero. 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 of the offense.
The Court emphasized that statutory rules on preserving the chain of custody are designed to ensure the integrity and reliability of evidence in drug cases. Section 21 of R.A. No. 9165 and its Implementing Rules require that immediately after seizure, the apprehending team must conduct a physical inventory and photograph the seized items in the presence of the accused or his representative, a representative from the media and the Department of Justice (DOJ), and any elected public official.
In this case, the prosecution failed to account for the initial custody of the seized drugs. The evidence showed that the poseur-buyer (the police asset) received the drugs from Relato and then handed them to PO3 Evasco. However, there was no testimony from the poseur-buyer himself to establish this crucial link. PO3 Evasco’s testimony alone on the transfer was insufficient. Furthermore, the prosecution did not offer any justifiable ground for the absence of the required witnesses (media, DOJ, elected official) during the inventory and photographing, nor did it show that the police had attempted to secure their presence. The marking of the evidence was done only at the police station, not at the place of seizure, without explanation. The failure to comply with the mandatory procedure, without any showing of justifiable cause, compromised the integrity and evidentiary value of the seized items. Consequently, the prosecution failed to prove Relato’s guilt beyond a reasonable doubt. The Court ordered his immediate release unless detained for another lawful cause.