G.R. No. 188024 ; June 5, 2013
RODRIGO RONTOS y DELA TORRE, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Police officers, conducting surveillance in Caloocan City, observed Rodrigo Rontos holding and scrutinizing two plastic sachets containing a white crystalline substance. They approached, confiscated the items, arrested him, and brought him to the station. The sachets were marked and later tested positive for shabu. Rontos was charged with illegal possession of dangerous drugs. The accused presented a contrasting version, claiming the police officers barged into his home, conducted a fruitless search, and then arrested him and a visitor in a frame-up.
The Regional Trial Court convicted Rontos, finding the prosecution’s evidence credible and the elements of the crime present. The Court of Appeals affirmed the conviction, ruling that any irregularity in his warrantless arrest was waived by his voluntary submission to the court’s jurisdiction. The CA also held that while the police failed to strictly comply with the chain of custody procedures under Section 21 of RA 9165, this did not impair the integrity of the seized drugs.

ISSUE

Whether the prosecution established the identity and integrity of the seized dangerous drugs beyond reasonable doubt, given the police officers’ non-compliance with the chain of custody requirements under Section 21, Article II of RA 9165.

RULING

The Supreme Court ACQUITTED Rodrigo Rontos on the ground of reasonable doubt. The Court held that while the accused validly waived any objection to the legality of his arrest by pleading not guilty and participating in trial, the prosecution’s failure to establish an unbroken chain of custody over the seized drugs was fatal to its case.
The legal logic centers on the imperative of proving the corpus delicti—the illegal drug itself—with moral certainty. In drug cases, this requires not just showing the drug’s existence but also ensuring its identity and integrity from seizure to presentation in court. The Court found a broken chain of custody. The police officers failed to conduct a physical inventory and photograph the seized items immediately after confiscation, as mandated by law. Furthermore, the prosecution did not offer any justifiable reason for this deviation from the prescribed procedure. The marking of the items at the police station, instead of at the place of seizure, created doubt about whether the drugs presented in court were the same ones taken from the accused. These lapses compromised the integrity of the evidence, creating reasonable doubt as to the very existence of the corpus delicti. Consequently, Rontos’ guilt could not be sustained beyond reasonable doubt.