G.R. No. 200075 . April 4, 2018.
SALIC MAPANDI y DIMAAMPAO, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioner Salic Mapandi was convicted by the Regional Trial Court for the illegal sale of 16.1 grams of shabu, a violation of Section 5, Article II of R.A. No. 9165 . The prosecution’s narrative was that a buy-bust operation was conducted where PO2 Javier, as poseur-buyer, received a white envelope containing the drugs from Mapandi in exchange for marked money. The defense, however, presented a starkly different account. Mapandi claimed he was in Olongapo for a legitimate cellphone trading business and was merely eating at a KFC when he was arbitrarily arrested and framed. He asserted the drugs were planted, raising the defense of instigation.
The RTC and the Court of Appeals both found the prosecution’s evidence credible, convicting Mapandi and sentencing him to life imprisonment. The CA held that while the police may not have strictly complied with the chain of custody procedure under Section 21 of R.A. No. 9165 , the integrity and evidentiary value of the seized drugs were allegedly preserved. Mapandi appealed to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the prosecution successfully established an unbroken chain of custody of the seized dangerous drug, thereby proving Mapandi’s guilt beyond reasonable doubt.

RULING

The Supreme Court REVERSED the CA decision and ACQUITTED Mapandi. The Court emphasized that in drug-related prosecutions, the identity and integrity of the corpus delicti must be established with moral certainty through an unbroken chain of custody. The procedure under Section 21 requires the immediate physical inventory and photographing of seized items in the presence of the accused or his representative, a media representative, a Department of Justice official, and an elected public official.
The Court found a broken chain of custody. The marking of the seized item—a critical first step in the custodial link—was not done immediately at the place of arrest. PO2 Javier testified he marked the plastic sachet only upon reaching the police station, without any justifiable explanation for the deviation. This failure cast serious doubt on whether the item presented in court was the same one allegedly seized from Mapandi. The prosecution’s narrative itself was inconsistent, with testimonies varying on whether the marking occurred at the scene or the station. The Court ruled that the prosecution failed to provide a credible explanation for these procedural lapses, which compromised the integrity of the evidence. Consequently, the identity of the corpus delicti was not proven beyond reasonable doubt, warranting acquittal.