G.R. No. 184546 , February 22, 2010
People of the Philippines, Appellee, vs. Wilson Suan y Jolongon, Appellant.

FACTS

On August 12, 2003, a buy-bust operation was conducted by PO2 Allan Labasano and PO1 Samsodim Gondol in Iligan City, resulting in the arrest of appellant Wilson Suan y Jolongon. PO1 Gondol acted as the buyer, and a sachet allegedly containing methamphetamine hydrochloride (shabu) was recovered. An Information was filed charging appellant with violation of Section 5, Article II of Republic Act No. 9165 , later amended to charge violation of Section 11 (illegal possession). The prosecution presented the police officers and Forensic Chemist Police Senior Inspector April Carvajal, who testified that the substance examined tested positive for shabu. Appellant denied the charge, claiming he was sleeping when arrested and that the shabu was planted. The Regional Trial Court found appellant guilty, a decision affirmed by the Court of Appeals. Appellant appealed to the Supreme Court, arguing inconsistencies in the testimonies of the police operatives and a failure to properly establish the identity of the illegal drug.

ISSUE

Whether the prosecution established the identity of the dangerous drug (the corpus delicti) beyond reasonable doubt, particularly in light of the chain of custody requirements.

RULING

The Supreme Court REVERSED the decision of the Court of Appeals and ACQUITTED appellant Wilson Suan y Jolongon. The Court held that the prosecution miserably failed to establish the identity of the substance allegedly seized from the appellant. The Certificate of Inventory prepared by PO2 Labasano did not indicate that he placed any identifying markings on the seized sachet. Furthermore, there was a break in the chain of custody: the evidence showed that the item submitted for laboratory examination was already marked “WSS” when received by the forensic chemist, but no witness testified as to who placed that marking or when it was placed. The police officers did not testify about marking the evidence, and the forensic chemist could only confirm receiving an already marked item. This gap cast doubt on the integrity and evidentiary value of the substance, failing to meet the requirement of proving an unbroken chain of custody. The Court emphasized that in drug cases, the identity of the narcotic substance must be established with moral certainty, and any gap in the chain of custody produces doubt as to the origin of the evidence. The inconsistencies in the testimonies regarding prior surveillance and marked money were deemed immaterial, but the failure to prove the identity of the corpus delicti was fatal to the prosecution’s case.