G.R. No. 205614 July 26, 2017
People of the Philippines, Plaintiff-Appellee vs. Jaime Segundo y Iglesias, Accused-Appellant

FACTS

Accused-appellant Jaime Segundo was charged with violating Section 5 of Republic Act No. 9165 (sale of dangerous drugs) following a buy-bust operation on July 6, 2003. A confidential informant tipped off police about Segundo’s drug activities. A team was formed, with PO1 Cesar Claveron acting as poseur-buyer. During the operation, Claveron allegedly bought one plastic sachet of shabu from Segundo using marked money. Upon the pre-arranged signal, the team arrested Segundo, who fled to his house. Inside, they coincidentally found co-accused Dominador Gubato allegedly repacking drugs. The seized items, including the sachet from the sale, were marked at the scene.
The prosecution’s evidence showed that the seized items were turned over to the investigating officer and subsequently delivered to the crime laboratory, where they tested positive for methamphetamine hydrochloride. However, the prosecution failed to present any testimony or evidence regarding who received the items at the laboratory, the condition upon receipt, or the specific chain of custody from the investigating officer to the forensic chemist.

ISSUE

Whether the prosecution established the guilt of the accused-appellant beyond reasonable doubt by proving an unbroken chain of custody over the seized dangerous drugs.

RULING

No. The Supreme Court acquitted accused-appellant Jaime Segundo. The Court emphasized that in drug cases, the identity and integrity of the corpus delicti must be established with moral certainty through an unbroken chain of custody. This includes every link: from seizure, marking, and inventory at the scene, to transfer to the police station, to submission for laboratory examination, and finally to presentation in court.
The prosecution’s evidence contained a critical gap in this chain. While witnesses testified to the seizure and marking at the scene, there was a complete absence of testimony regarding the crucial transfer of the evidence from the investigating officer to the forensic chemist. No evidence was presented to show who received the items at the laboratory, their condition upon receipt, or the procedures followed to safeguard them. This gap created reasonable doubt as to whether the items presented in court were the same ones seized from the accused. The miniscule quantity of the drug (0.03 gram) only heightened the need for strict compliance with the chain of custody procedure. The prosecution’s failure to account for every link, without offering any justifiable ground for the lapse, compromised the integrity of the evidence and warranted acquittal.