G.R. No. 208095 , September 20, 2017
People of the Philippines, Plaintiff-Appellee vs. Jefferson Del Mundo y Abac and Mitos Lacson-Del Mundo, Accused-Appellants

FACTS

Accused-appellants Jefferson Del Mundo and Mitos Lacson-Del Mundo were charged with illegal sale of dangerous drugs under Republic Act No. 9165 . Jefferson was separately charged with illegal possession. The prosecution alleged that on May 10, 2005, a buy-bust operation was conducted in Calapan City. P03 Mariel Rodil acted as poseur-buyer and was introduced by a confidential informant to Mitos. After receiving marked money, Mitos asked Jefferson for “halagang dalawang piso,” and Jefferson handed a sachet of shabu to Rodil. Upon the pre-arranged signal, backup officers arrested Mitos and pursued Jefferson into a house. Jefferson was apprehended in a toilet, where he was seen throwing four plastic sachets into the bowl, which were later retrieved.
The defense presented a starkly different version. Jefferson testified he was in the comfort room when police forcibly entered their home without a warrant, manhandled him, and planted the drugs. Mitos claimed she was merely washing clothes outside when she was arbitrarily arrested. They asserted the buy-bust was a frame-up and denied any drug transaction. The Regional Trial Court convicted both accused, a decision affirmed by the Court of Appeals, leading to this final appeal.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellants beyond reasonable doubt for the crimes of illegal sale and illegal possession of dangerous drugs, with particular regard to the integrity and evidentiary value of the seized items.

RULING

The Supreme Court ACQUITTED both accused-appellants. The prosecution failed to establish an unbroken chain of custody over the seized drugs, which is crucial to proving the corpus delicti. The Court noted glaring inconsistencies in the testimonies of the police officers regarding the marking of the evidence. P03 Rodil testified she marked the sachet from the sale at the police station. However, SPO2 Espiritu claimed he saw Rodil mark it at the scene. This discrepancy creates doubt about when and by whom the critical initial marking was done, compromising the identity of the evidence from the very point of seizure.
Furthermore, the Court found the buy-bust operation itself highly questionable. The alleged transaction—where Mitos asked for “halagang dalawang piso” (two pesos’ worth) from Jefferson—was illogical and did not conform to the typical manner of drug sales, casting doubt on its occurrence. The defense of frame-up and irregular arrest was deemed credible given the police officers’ inconsistent narratives and the failure to strictly comply with the witness requirements under Section 21 of RA 9165 during inventory. The totality of these procedural lapses and inconsistencies created reasonable doubt. Consequently, the presumption of innocence prevailed, and the accused-appellants were ordered released.