G.R. No. 193862 , October 01, 2019
ELIZABETH SARANILLAS-DELA CRUZ AND HENRY DELA CRUZ, PETITIONERS, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

Petitioners Elizabeth Saranillas-Dela Cruz and Henry Dela Cruz, along with a co-accused, were charged with illegal sale of dangerous drugs (Criminal Case No. Q-03-116540). Henry Dela Cruz was separately charged with illegal possession of dangerous drugs (Criminal Case No. Q-03-116542). The prosecution’s version, based on a buy-bust operation, stated that on April 6, 2003, in Quezon City, PO1 Jose Teraña acted as a poseur-buyer and bought a sachet of shabu from “Mommy Beth” (Elizabeth) for P100.00. Elizabeth received the money and, after whispering to Henry, obtained a sachet from him which she handed to Teraña. Upon arrest, the buy-bust money was recovered from Elizabeth, and one sachet each was found in the pockets of Henry and the co-accused. The seized items were marked and later confirmed by forensic examination to be Methylamphetamine hydrochloride. The defense claimed no buy-bust operation occurred, alleging instead that police raided their house on April 4, 2003, and forcibly brought them to the station. The Regional Trial Court convicted the petitioners. The Court of Appeals affirmed the convictions. During the appeal, the Supreme Court was informed of Elizabeth’s death on June 12, 2017, which extinguished her criminal liability. Thus, the appeal proceeded only for Henry Dela Cruz.

ISSUE

Whether the conviction of Henry Dela Cruz for violations of Sections 5 and 11 of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act) should be reversed due to the prosecution’s failure to establish an unbroken chain of custody of the seized dangerous drugs, thereby failing to prove his guilt beyond reasonable doubt.

RULING

Yes. The Supreme Court REVERSED and SET ASIDE the decision of the Court of Appeals, and ACQUITTED Henry Dela Cruz. The Court emphasized that in prosecutions for illegal sale and possession of dangerous drugs, the identity of the drugs constituting the corpus delicti must be established with moral certainty through an unbroken chain of custody. The prosecution must account for each link in the chain: (1) seizure and marking, (2) turnover to the investigating officer, (3) turnover to the forensic chemist for examination, and (4) presentation in court. The Court found that the seizing officers committed significant lapses. The testimony of PO1 Teraña revealed that after confiscating the sachets from the accused, he marked them at the police station. However, there was no testimony on who had custody of the drugs between their confiscation and marking at the station, nor on who delivered them to the crime laboratory and who received them there. These gaps constituted a broken chain of custody. The law requires strict compliance with the chain of custody procedure; any deviation is allowed only upon justifiable grounds and provided the integrity and evidentiary value of the seized items are preserved. The prosecution failed to offer any justification for the lapses, and the integrity of the evidence was consequently compromised. Therefore, the prosecution failed to prove Dela Cruz’s guilt beyond reasonable doubt. The Court ordered his immediate release. Regarding Elizabeth Saranillas-Dela Cruz, the criminal case against her was dismissed due to her death prior to the finality of the judgment.