G.R. No. 206927 , July 13, 2016
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. DARIUS RENIEDO Y CAUILAN, Accused-Appellant.

FACTS

The prosecution’s case stemmed from a buy-bust operation on April 27, 2004, in San Juan. A confidential informant reported drug-selling activity, leading a police team to designate PO1 Gener Antazo as the poseur-buyer. Antazo testified that he approached appellant Darius Reniedo, who was playing cards, and used coded language to request drugs. Appellant allegedly sold one plastic sachet of shabu for marked money. Upon Antazo’s signal, backup officers arrested appellant, and a subsequent search yielded two more sachets from a candy case in his pocket. The seized items were marked and later tested positive for methamphetamine hydrochloride. Based on this, appellant was charged with illegal sale and possession of dangerous drugs under Republic Act No. 9165 .
The defense presented a starkly different account. Appellant testified that he was merely playing cards with neighbors when police officers arrived and frisked them. He claimed he was brought to the station where an officer attempted to extort money, and when he refused, he was falsely charged. The Regional Trial Court convicted appellant, crediting the lone testimony of PO1 Antazo and applying the presumption of regularity in the performance of official duties. The Court of Appeals affirmed this decision, prompting the appeal to the Supreme Court.

ISSUE

Whether the prosecution successfully established the identity and integrity of the seized dangerous drugs, thereby proving appellant’s guilt beyond reasonable doubt for violations of Sections 5 and 11 of R.A. No. 9165 .

RULING

The Supreme Court REVERSED the appellate court’s decision and ACQUITTED appellant. The ruling hinged on the prosecution’s fatal failure to establish an unbroken chain of custody over the seized drugs, which compromised their identity and integrity as evidence. The Court emphasized that in drug cases, the State must account for each link in the chain: seizure, marking, turnover to investigating officer, turnover to forensic chemist, and presentation in court.
The legal logic centered on non-compliance with Section 21 of R.A. No. 9165 and its implementing rules. PO1 Antazo testified that he merely handed the seized sachets to PO1 Rio Tuyay at the station, who then delivered them to the crime laboratory. However, the prosecution did not present PO1 Tuyay or the forensic chemist to testify, nor did it offer any justifiable reason for these witnesses’ absence. This created a significant gap in the chain. The marking of evidence, a crucial first step in ensuring integrity, was also inadequately established, as the testimony did not clearly specify when and where it was done in relation to the accused. These procedural lapses, unexplained and unjustified, negated the presumption of regularity in the police officers’ conduct. Consequently, the identity of the corpus delicti was rendered doubtful, leading to reasonable doubt as to appellant’s guilt. The Court reiterated that strict adherence to chain-of-custody procedure is paramount, and its breach warrants acquittal.