GR 195043; (November, 2017) (Digest)
G.R. No. 195043 November 20, 2017
ARNEL CALAHI, ENRIQUE CALAHI, AND NICASIO RIVERA, Petitioners, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
Petitioners were charged with illegal possession and use of dangerous drugs under Section 16, Article III of R.A. No. 6425. The prosecution alleged that on November 20, 1997, police officers, while serving a search warrant at a nearby house in Cabanatuan City, noticed an XLT jeep and saw petitioners and another accused inside holding a pot session. The officers arrested them and confiscated a white crystalline substance, later confirmed as 0.36 grams of shabu. The defense presented a different version, claiming they were merely parked to inquire about a baptism when police arrived, searched their vehicle and found nothing, but still brought them to the station.
The Regional Trial Court convicted petitioners, finding the prosecution witnesses credible. The Court of Appeals affirmed the conviction, upholding the trial court’s assessment of witness credibility and finding all elements of the crime proven beyond reasonable doubt.
ISSUE
Whether the prosecution proved the guilt of the petitioners beyond reasonable doubt, particularly in establishing the identity and integrity of the confiscated dangerous drug.
RULING
The Supreme Court REVERSED the appellate decision and ACQUITTED the petitioners. The Court emphasized that in drug-related prosecutions, the State must prove with moral certainty the identity of the prohibited drug, as its very existence constitutes the corpus delicti of the offense. This requires an unbroken chain of custody over the seized item from the moment of confiscation until its presentation in court.
The prosecution failed to establish this crucial chain. The testimonies of the apprehending officers were inconsistent and insufficient regarding who had initial custody, how the item was handled, and how it was transmitted to the forensic chemist. SPO3 Padilla testified that he marked the seized item at the police station, but another officer, SPO1 Mendoza, claimed he was the one who delivered it to the crime laboratory. The forensic analyst, Kathlyn Vigilia, testified she received the item from an unnamed police officer, creating a significant gap in the custody trail. These inconsistencies and the failure to account for every link in the chain created reasonable doubt as to whether the shabu presented in court was the same substance allegedly seized from the petitioners. Consequently, the prosecution did not overcome the constitutional presumption of innocence.