G.R. No. 194945; July 30, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ALEX WATAMAMA y ESIL, Accused-Appellant.

FACTS

The prosecution alleged that based on a tip, a buy-bust operation was conducted against appellant Alex Watamama for selling illegal drugs. PO1 Peggy Lynne Vargas acted as the poseur-buyer and purchased P200 worth of shabu from the appellant. Upon consummation of the sale, the team arrested Watamama and recovered the marked money. The seized plastic sachet, later confirmed to contain 0.18 grams of methylamphetamine hydrochloride, was marked by PO1 Vargas at the police station. An inventory was prepared and signed, and the item was forwarded to the crime laboratory for examination. The defense presented a different narrative, claiming the appellant was arbitrarily arrested in his home without a warrant and that no drugs were found on him. He was allegedly pressured to reveal a drug supplier.
The Regional Trial Court convicted Watamama of illegal sale of dangerous drugs under Section 5 of Republic Act No. 9165 and sentenced him to life imprisonment and a fine. The Court of Appeals affirmed the conviction, ruling that the chain of custody was established and that the marking and inventory at the police station, instead of the place of arrest, were justified due to the forming crowd. The CA also held that a defect in pre-operation coordination with the PDEA was not fatal. The appellant elevated the case to the Supreme Court, contending that the prosecution failed to establish an unbroken chain of custody of the seized drugs.

ISSUE

Whether the prosecution successfully established the identity and integrity of the seized dangerous drug, constituting the corpus delicti, through an unbroken chain of custody as required by law.

RULING

The Supreme Court reversed the appellate court’s decision and acquitted the accused. The Court emphasized that in drug-related prosecutions, the identity of the prohibited drug must be established with moral certainty, and every link in the chain of custody must be accounted for to ensure the integrity of the evidence presented in court is the same item seized from the accused. While strict, not perfect, adherence to the procedural requirements of Section 21 of R.A. No. 9165 is permitted, the prosecution must provide a justifiable reason for any lapse and must positively demonstrate that the integrity and evidentiary value of the seized items were preserved.
In this case, the prosecution failed to meet this burden. The Court found a critical gap in the chain of custody. The testimony only established that PO1 Vargas turned over the seized shabu to an investigator at the station, and that a certain PO2 Ortiz later brought it to the crime lab. Crucially, there was a complete absence of testimony or evidence detailing how the evidence was handled, stored, or transferred between the investigator and PO2 Ortiz. This unexplained gap compromised the identity of the corpus delicti. Without establishing every link in the chain, the prosecution failed to prove the integrity of the evidence beyond reasonable doubt. Consequently, the appellant’s acquittal was warranted.