G.R. No. 179757, September 13, 2017
Leonardo P. Casona, Petitioner, vs. People of the Philippines, Respondents.

FACTS

The petitioner, Leonardo P. Casona, was charged with illegal possession of dangerous drugs under Section 11 of Republic Act No. 9165. The prosecution alleged that on February 6, 2004, police officers, acting on a tip, conducted a surveillance operation in Mandaluyong City. They claimed to have witnessed Casona and a companion exchanging a plastic sachet on a street. Upon approach, the companion fled, and Casona was arrested. The arresting officer, PO1 Madlangbayan, testified that he recovered a plastic sachet from Casona’s hand and another from his pocket, which were later confirmed to contain methamphetamine hydrochloride or shabu.
Casona presented a different version, asserting he was merely on his way to an off-track betting station when he was arbitrarily arrested. The Regional Trial Court convicted him, and the Court of Appeals affirmed the conviction, heavily relying on the presumption of regularity in the performance of official duties by the arresting officers and finding that the integrity of the seized items was preserved.

ISSUE

Whether the Court of Appeals erred in affirming the conviction despite alleged weaknesses in the prosecution’s evidence, particularly concerning the compliance with the chain of custody requirements under Republic Act No. 9165.

RULING

The Supreme Court REVERSED the decision and ACQUITTED Leonardo P. Casona. The Court emphasized that in prosecutions for illegal possession of dangerous drugs, the State must prove not only the elements of the crime but also the integrity and identity of the corpus delicti through an unbroken chain of custody. The law requires strict compliance with the procedure for the seizure, custody, and disposition of drugs to prevent tampering or substitution.
The Court found that the prosecution failed to establish an unbroken chain of custody. The records did not show that the required witnesses—an elected public official, a representative from the Department of Justice, and a media representative—were present during the inventory and photography of the seized items as mandated by Section 21 of RA 9165. The police officers offered no justifiable reason for this non-compliance. Consequently, the presumption of regularity in the performance of official duties could not apply, as it is premised on a showing of compliance with standard procedures. The identity and integrity of the seized drugs were therefore compromised, creating reasonable doubt. The Court ruled that the conviction could not stand based on the broken chain of custody, which fatally undermined the prosecution’s case.