G.R. No. 174773. October 2, 2007.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARILYN MIRANDA y RAMA, accused-appellant.

FACTS

The prosecution’s case, anchored on the testimony of PO1 Henry Valenzuela, alleged that a buy-bust operation was conducted against appellant Marilyn Miranda on January 12, 2004, in Aritao, Nueva Vizcaya. PO1 Valenzuela acted as the poseur-buyer, accompanied by an informant, Reynaldo Mazo. Upon introduction, Mazo informed appellant of the need to buy shabu. Appellant allegedly sought permission from her co-accused, Imeldo Caoile, before retrieving four heat-sealed plastic sachets from a room and handing them to Mazo in exchange for a marked P500 bill. PO1 Valenzuela then gave the pre-arranged signal, leading to appellant’s arrest. The seized items were later marked at the police station and subsequently confirmed by forensic examination to be methamphetamine hydrochloride.
The defense presented a starkly different narrative. Appellant and Caoile testified that on the evening in question, Mazo and PO1 Valenzuela arrived at their house. Appellant conversed with them while Caoile remained in the kitchen. Suddenly, several men barged in, searched the premises, and claimed to have found shabu. They were then taken to the police station. The defense denied any sale transaction, insinuating the evidence was fabricated.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt the elements of illegal sale of dangerous drugs under Section 5, Article II of Republic Act No. 9165.

RULING

The Supreme Court acquitted appellant. The conviction was reversed due to the prosecution’s failure to establish an unbroken chain of custody over the seized drugs, a critical requirement in drug cases. The legal logic hinges on the imperative to remove any doubt of evidence tampering or substitution. The Court noted glaring gaps in the procedure: the arresting officer, PO1 Valenzuela, did not immediately mark the seized sachets at the place of arrest. Instead, the marking was done by another officer, PO1 Vergara, only at the police station, without a clear account of who had possession of the drugs in the interim. Furthermore, the prosecution did not offer any justifiable explanation for this deviation from the standard procedure outlined in Section 21 of RA 9165, which requires immediate inventory and photographing of seized items in the presence of specified witnesses. These lapses in the chain of custody compromised the integrity and identity of the corpus delicti. Without the assurance that the evidence presented in court was the very same substance seized from appellant, her guilt cannot be sustained. The presumption of innocence must prevail.