G.R. No. 189330, November 28, 2012
People of the Philippines, Plaintiff-Appellee, vs. Louie Catalan y Dedala, Accused-Appellant.

FACTS

Accused Louie Catalan was convicted by the Regional Trial Court for illegal sale of shabu under Section 5 of Republic Act No. 9165, based on a buy-bust operation. The prosecution evidence, primarily from PO1 Alaindelon Ignacio, stated that on February 8, 2004, Catalan sold two plastic sachets of shabu to the poseur-buyer at a billiard hall. Upon arrest, the police recovered the buy-bust money and the sachets. The defense presented a starkly different version, alleging that policemen barged into his home, arrested him without cause, and later demanded money for his release, framing him for the offense.
The forensic chemist was not presented as a witness after the defense admitted the existence of the Request for Laboratory Examination and the Chemistry Report. The RTC and the Court of Appeals both convicted Catalan, giving credence to the police testimony and applying the presumption of regularity in the performance of official duties.

ISSUE

Whether the prosecution proved the accused’s guilt for illegal sale of dangerous drugs beyond reasonable doubt, particularly by establishing an unbroken chain of custody of the seized items.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED the accused. The Court emphasized that in drug-related prosecutions, the State must prove with moral certainty the identity of the prohibited drug, ensuring its integrity from seizure to presentation in court. This requires an unbroken chain of custody. The Court found critical gaps in the links of custody established by the prosecution.
The arresting officer, PO1 Ignacio, testified that he marked the seized sachets at the police station. However, the marking on the evidence presented in court (“B LCD 020804”) differed from the marking he testified to placing (“BLCO 020804”). This discrepancy created doubt about whether the items examined were the same ones seized from the accused. Furthermore, the prosecution failed to account for the handling and transfer of the evidence from the investigator to the forensic chemist. The mere admission of the laboratory report did not substitute for demonstrating the chain of custody through testimony. These lapses breached the integrity of the evidence. Consequently, the presumption of regularity in the police officers’ performance could not apply, as it arises only from an established basic fact of regularity, which was absent. The prosecution’s failure to establish an unbroken chain of custody warranted acquittal on grounds of reasonable doubt.