G.R. No. 184595; June 29, 2010
PEOPLE OF THE PHILIPPINES, Appellee, vs. SAPIA ANDONGAN y SANDIGANG, Appellant.

FACTS

Appellant Sapia Andongan was charged with violating Section 5 of R.A. No. 9165 (Comprehensive Dangerous Drugs Act of 2002) for allegedly selling 0.146 grams of shabu in a buy-bust operation on June 25, 2004. The prosecution’s case, anchored primarily on the testimony of PO2 Elymar Garcia, stated that a team conducted the operation based on a tip. PO2 Garcia acted as poseur-buyer, handing a marked ₱500 bill to appellant, who in turn gave him a plastic sachet containing a white crystalline substance. Upon receiving the item, PO2 Garcia arrested appellant. The seized item was later confirmed by forensic examination to be shabu. The Regional Trial Court convicted appellant, sentencing her to life imprisonment and a fine. The Court of Appeals affirmed the conviction.
The defense presented a different version, claiming appellant was merely bringing dinner to her husband at his workplace when six armed men apprehended her, brought her to the police precinct, and took her money. Appellant assailed her conviction, questioning the credibility of the sole prosecution witness, the failure to present the team leader to corroborate, the improbability of the scenario, and the integrity of the chain of custody of the seized drug.

ISSUE

Whether the prosecution proved appellant’s guilt for illegal sale of dangerous drugs beyond reasonable doubt, particularly in establishing the identity and integrity of the corpus delicti through an unbroken chain of custody.

RULING

The Supreme Court REVERSED the Court of Appeals’ decision and ACQUITTED appellant. The prosecution failed to establish an unbroken chain of custody of the seized shabu, which is crucial in proving the identity of the corpus delicti beyond reasonable doubt. PO2 Garcia’s testimony revealed critical gaps. He admitted that after seizing the sachet and arresting appellant, he did not immediately mark the evidence. He stated he saw the team leader, SPO3 del Rosario, “rushing for assistance,” but it was unclear who had custody of the drug between the arrest and its turnover at the police station. The testimony failed to detail who specifically had possession, when and where the marking was done, and how the item was handled and preserved until its laboratory examination.
The Court emphasized that in drug cases, the State must account for each link in the chain: from seizure, to marking, to turnover to investigating officers, to delivery to the forensic laboratory, and finally to its presentation in court. Any break in this chain raises reasonable doubt about the identity and integrity of the evidence, which is fatal to the prosecution’s case. Given these substantial lapses, which were not justified, the integrity of the very drug presented as evidence was compromised. Consequently, appellant’s guilt was not proven to the required moral certainty, warranting acquittal.