G.R. No. 174774 ; August 31, 2011
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ROLANDO S. DELOS REYES, alias “Botong,” and RAYMUNDO G. REYES, alias “Mac-Mac,” Accused-Appellants.

FACTS

On February 17, 2000, accused-appellants Rolando S. delos Reyes and Raymundo G. Reyes, along with Emmanuel de Claro and Mary Jane Lantion-Tom, were arrested for illegal possession, sale, delivery, distribution, and/or transportation of 980.9 grams of Methamphetamine Hydrochloride (shabu). An Information was filed against them for violation of R.A. No. 6425 (Dangerous Drugs Act). After a reinvestigation, the City Prosecutor recommended proceeding against Raymundo Reyes and Emmanuel de Claro, but dismissing the charges against Rolando delos Reyes and Lantion-Tom. However, the trial court proceeded with the trial against all accused.
The prosecution’s version, based on the arresting officers’ Joint Affidavit, was that a buy-bust operation took place at the Shangrila Plaza Hotel parking area in Mandaluyong City. The officers claimed they witnessed a drug transaction where de Claro handed a box containing shabu to delos Reyes, who then handed it to Raymundo Reyes, leading to their arrest.
The defense presented a different account. Rolando delos Reyes claimed he was forcibly arrested by armed men in Buenas Market, Pasig City, while looking for Raymundo Reyes regarding a debt. He was blindfolded, taken to Camp Bagong Diwa, and shown a bag of shabu he knew nothing about. This was supported by a Barangay Blotter entry made by his wife and a witness, Joel Navarro. Raymundo Reyes and Emmanuel de Claro denied the buy-bust story, claiming they were at the Whistlestop Bar and Restaurant on unrelated business when suddenly arrested.
The Regional Trial Court convicted all accused. On appeal, the Court of Appeals affirmed the conviction of accused-appellants Rolando delos Reyes and Raymundo Reyes but acquitted Emmanuel de Claro and Mary Jane Lantion-Tom. The CA found the prosecution’s evidence sufficient to prove guilt beyond reasonable doubt. Accused-appellants then appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellants Rolando S. delos Reyes and Raymundo G. Reyes for violation of Section 21, Article IV in relation to Section 16, Article III of R.A. No. 6425 , despite alleged inconsistencies in the prosecution’s evidence and the defense’s claim of a frame-up.

RULING

The Supreme Court REVERSED and SET ASIDE the Decision of the Court of Appeals. Accused-appellants Rolando S. delos Reyes and Raymundo G. Reyes were ACQUITTED on the ground of reasonable doubt. The Court ordered their immediate release unless detained for another lawful cause.
The Court found the prosecution failed to prove the guilt of the accused-appellants beyond reasonable doubt. Key deficiencies included:
1. Inconsistencies in the Arrest Location: The prosecution’s sole witness, PO3 Rodelio Bautista, testified during trial that the arrest and seizure happened at a parking area on Boni Avenue, Mandaluyong City. This directly contradicted the Joint Affidavit of Arrest, which stated the operation was at the Shangrila Plaza Hotel parking area. The prosecution offered no explanation for this major discrepancy, which cast serious doubt on the integrity of the police operation’s narrative.
2. Break in the Chain of Custody: The prosecution failed to establish an unbroken chain of custody of the seized drugs, which is crucial in drug cases. PO3 Bautista admitted he did not personally mark the seized items at the place of arrest. He first saw the evidence only at the police station when it was presented to him for marking. There was no testimony on who had possession of the drugs from the time of seizure until they were marked at the station. This gap compromised the identity and integrity of the corpus delicti.
3. Failure to Rebut Defense of Frame-up: The defense presented evidence, including a Barangay Blotter, to support delos Reyes’s claim that he was arrested in Pasig City, not Mandaluyong, and that the shabu was planted. The prosecution did not present the other arresting officers to refute this claim or explain the blotter. The trial court’s dismissal of the blotter as “hearsay” was erroneous, as it was offered not for the truth of the kidnapping but to prove that the incident was reported, corroborating the defense’s alternative narrative of arrest.
Given the material inconsistencies in the prosecution’s story, the broken chain of custody, and the unrebutted evidence suggesting a possible frame-up, the Court held that the evidence did not meet the required moral certainty for conviction. The presumption of innocence prevailed.