GR 206590; (March, 2017) (Digest)
G.R. No. 206590 March 27, 2017
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs MYRNA GAYOSO y ARGUELLES, Accused-Appellant
FACTS
Accused-appellant Myrna Gayoso was charged with illegal sale and possession of shabu. The prosecution alleged that after a surveillance and confirmatory test-buy operation on March 24, 2004, a police poseur-buyer purchased a sachet of shabu from Gayoso. A team then implemented a search warrant at her residence, where they allegedly found eleven more sachets of shabu. The seized items were marked, inventoried, and later confirmed by laboratory examination to be methamphetamine hydrochloride.
Gayoso denied the accusations, claiming the evidence was planted. She asserted that police officers forcibly entered her home and that the search warrant was only shown to her an hour later, alleging a motive of ill will due to a prior quarrel with a police officer’s family. The Regional Trial Court and the Court of Appeals found her guilty, emphasizing the positive identification by police witnesses and the established chain of custody of the seized drugs.
ISSUE
Whether the prosecution proved the guilt of the accused beyond reasonable doubt for violations of Sections 5 and 11, Article II of Republic Act No. 9165 , particularly in preserving the integrity and evidentiary value of the seized dangerous drugs through an unbroken chain of custody.
RULING
The Supreme Court REVERSED the convictions and ACQUITTED Myrna Gayoso. The Court emphasized that in drug-related prosecutions, the identity of the corpus delicti must be established with moral certainty, requiring an unbroken chain of custody. The Court found that the police officers committed glaring breaches of the chain of custody procedure under Section 21 of RA 9165. Crucially, the required witnesses during the physical inventory and photographing of the seized items were not present. The law mandates the presence of a representative from the media, the Department of Justice, and any elected public official. The prosecution only presented a barangay chairman and a kagawad, failing to justify the absence of the other required witnesses. This failure cast serious doubt on the integrity of the seized drugs, as the broken chain of custody compromised their identity as the very items seized from the accused. The presumption of regularity in the performance of official duty could not arise due to these procedural lapses. Consequently, the guilt of the accused was not proven beyond reasonable doubt.