G.R. No. 188107; December 05, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RONALD M. DEL ROSARIO @ “AGING”, Accused-Appellant.

FACTS

Accused-appellant Ronald Del Rosario was charged with illegal sale of dangerous drugs under Section 5, Article II of Republic Act No. 9165. The prosecution’s narrative, based on police testimonies, detailed a buy-bust operation on April 26, 2003, in Las Piñas City. A confidential informant alerted authorities about Del Rosario’s drug activities. A team was formed, with PO3 Herminio Besmonte acting as poseur-buyer using a marked ₱100 bill. The team proceeded to the target area where the informant introduced Besmonte to Del Rosario. The prosecution alleged that Besmonte handed the marked money to Del Rosario, who in turn gave a plastic sachet containing white crystalline substance. Upon consummation of the sale, Besmonte gave a pre-arranged signal, leading to Del Rosario’s arrest. The seized item was marked and later confirmed by forensic examination to be 0.03 gram of shabu.
In contrast, the defense presented a starkly different account. Del Rosario and his witness, Saulito Granada, claimed the arrest was illegitimate. They testified that police officers in civilian clothes forcibly entered Del Rosario’s house without a warrant, ransacked it, and found nothing illegal before arresting him. Del Rosario alleged the charge was fabricated after he refused an extortion attempt by the arresting officers. The defense thus interposed denial and frame-up, asserting that no legitimate buy-bust operation occurred.

ISSUE

The core issue is whether the prosecution successfully proved Del Rosario’s guilt for illegal sale of shabu beyond reasonable doubt, particularly in establishing the identity and integrity of the corpus delicti amidst conflicting narratives and alleged procedural lapses in the chain of custody.

RULING

The Supreme Court acquitted Del Rosario. The ruling hinged on the prosecution’s failure to establish an unbroken chain of custody of the seized drugs, which is crucial in proving the corpus delicti. The Court noted glaring inconsistencies and gaps in the testimony regarding the handling of the evidence. PO3 Besmonte, the poseur-buyer, testified that he marked the plastic sachet with “RMR-April 26, ’03” at the police station before turning it over to the investigator, PO3 Dalagdagan. However, PO2 Jerome Mendoza testified that it was Dalagdagan who marked the sachet with “RMR” and “April 27, 03” upon receipt. This discrepancy in who marked the evidence and the variance in the recorded date created reasonable doubt about the identity and integrity of the very item allegedly bought from Del Rosario.
The Court emphasized that in drug cases, the State must account for each link in the chain of custody—from seizure, to marking, to turnover for laboratory examination. The irreconcilable testimonies on this vital procedure breached the chain. The defense of denial and frame-up gained credibility in light of this procedural failure. Consequently, the presumption of innocence prevailed. The guilt of the accused was not proven beyond the shadow of a doubt, warranting acquittal. The decision of the Court of Appeals was reversed and set aside.