G.R. No. 212940 , September 16, 2015
CHRISTOPHER DELA RIVA Y HORARIO, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

An Information was filed charging Christopher Dela Riva with violation of Section 5, Article II of R.A. No. 9165 (Comprehensive Dangerous Drugs Act of 2002) for allegedly selling one heat-sealed plastic sachet of methamphetamine hydrochloride (“shabu”) to a poseur-buyer on April 28, 2009, in Subic, Zambales. The prosecution’s evidence, based on the testimonies of PDEA agents, established that a buy-bust operation was conducted after a confidential agent reported Dela Riva’s illegal drug activities. IO1 Enrique Lucero acted as the poseur-buyer. During the operation, Dela Riva handed a plastic sachet of shabu to Lucero, who then gave the boodle money in exchange. Upon consummation of the sale, Dela Riva was arrested. The seized item was marked, and an inventory was conducted at the PDEA National Headquarters, witnessed by a Barangay Kagawad. Laboratory examination confirmed the substance was shabu. The defense presented a version of frame-up, alleging Dela Riva was arrested on April 26, 2009, and brought to PDEA headquarters where he was forced to sign documents. The Regional Trial Court (RTC) convicted Dela Riva, and the Court of Appeals (CA) affirmed the conviction.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of petitioner Christopher Dela Riva for violation of Section 5, Article II of R.A. No. 9165 .

RULING

The Supreme Court REVERSED the CA decision and ACQUITTED Christopher Dela Riva. The Court found that the prosecution failed to establish an unbroken chain of custody of the seized dangerous drug, which is crucial in proving the corpus delicti of the offense. The apprehending team did not comply with the mandatory procedures under Section 21, Article II of R.A. No. 9165 . Specifically, the physical inventory and photographing of the seized items were not conducted immediately at the place of arrest but only later at the PDEA National Headquarters in Quezon City. The prosecution did not offer any justifiable reason for this deviation, nor did it present the required witnesses (an elected public official, a representative from the media, and a representative from the Department of Justice) during the inventory. The lone presence of a Barangay Kagawad was insufficient. The failure to adhere to the prescribed procedure, without any showing of justifiable grounds, compromised the integrity and evidentiary value of the seized item. Consequently, the identity of the corpus delicti was not proven with moral certainty, warranting acquittal based on reasonable doubt.