G.R. No. 200304 ; January 15, 2014
People of the Philippines, Plaintiff-Appellee, vs. Donald Vasquez y Sandigan @ “Don,” Accused-Appellant.

FACTS

Accused-appellant Donald Vasquez was charged with illegal sale and illegal possession of methamphetamine hydrochloride or shabu. The prosecution alleged that on April 3, 1998, a buy-bust operation was conducted against Vasquez, who claimed to be an NBI employee. After a series of meetings, the transaction was set near his apartment. The poseur-buyer, Police Inspector Jean Fajardo, testified that Vasquez handed over a brown envelope containing six plastic sachets of shabu, and she gave the pre-arranged signal upon receipt. The arresting team then apprehended Vasquez, and a subsequent search yielded twelve more sachets from his pocket.
The defense presented a starkly different version, claiming the charges were fabricated. Vasquez testified that on the night in question, he was at home with his family when several armed men forcibly entered, handcuffed him, and brought him to a police station where he was framed. He asserted the evidence was planted and denied any involvement in drug trafficking.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for the crimes of illegal sale and illegal possession of dangerous drugs beyond reasonable doubt.

RULING

The Supreme Court acquitted the accused-appellant. The conviction was reversed due to the prosecution’s failure to establish an unbroken chain of custody over the seized drugs, which is crucial in proving the corpus delicti. The Court found a significant gap in the evidence regarding the handling of the drugs immediately after seizure. The testimony of the forensic chemist, P/Insp. Marilyn Dequito, revealed that the request for laboratory examination and the specimens themselves were delivered to her by a person not identified or presented in court. This person was not a member of the buy-bust team, and there was no testimony detailing how this individual received the items or from whom.
This break in the chain of custody creates reasonable doubt as to whether the items presented in court were the same ones seized from the accused. The prosecution did not offer any justifiable reason for this lapse. Consequently, the integrity and evidentiary value of the corpus delicti were compromised. The Court emphasized that in drug cases, the State must account for each link in the chain—from seizure, to marking, to turnover for laboratory examination, to submission to the court. The unexplained transfer to an unidentified courier constitutes a fatal procedural flaw. Therefore, the presumption of innocence prevails, and the accused is entitled to an acquittal.