G.R. No. 213922 , July 5, 2017
People of the Philippines, Plaintiff-Appellee vs. Rommel Diputado, Accused-Appellant

FACTS

The prosecution alleged that based on a tip and a prior test buy, a buy-bust operation was conducted against accused-appellant Rommel Diputado for selling dangerous drugs. PO1 Estares, as poseur-buyer, handed marked money to Diputado in exchange for a plastic sachet containing white crystalline substance. Upon consummation, Diputado was arrested, and the marked money was recovered. The seized item was later marked, inventoried, and submitted for laboratory examination, which confirmed it was methamphetamine hydrochloride.
The defense presented a starkly different version. Diputado claimed he was merely riding a taxi on his way to butcher a pig for a friend when his vehicle was blocked. He was forcibly taken to a barangay captain’s house where money and shabu were presented, and he was coerced to point at them for a photograph. He denied any involvement in a drug sale.

ISSUE

Whether the prosecution proved the guilt of the accused-appellant for illegal sale of dangerous drugs beyond reasonable doubt, particularly in establishing the integrity and evidentiary value of the seized item through strict compliance with the chain of custody rule under Section 21 of Republic Act No. 9165 .

RULING

The Supreme Court REVERSED the conviction and ACQUITTED accused-appellant. The prosecution failed to establish an unbroken chain of custody, creating reasonable doubt on the integrity of the evidence. The Court emphasized that in drug cases, the identity of the corpus delicti must be established with moral certainty. The procedural requirements under Section 21 of R.A. 9165 are crucial to this purpose.
The legal logic is that the buy-bust team committed unjustified deviations from the prescribed chain of custody. First, the required witnesses—an elected public official, a representative from the Department of Justice, and a media representative—were not present at the time and place of seizure and marking. The marking was done later at the police station without these witnesses. Second, the prosecution offered no explanation for this non-compliance. While strict compliance may not always be required, justifiable grounds for deviation must be proven. The prosecution’s failure to show any compelling reason for the lapse, such as threats to officer safety or genuine unavailability of witnesses, was fatal to its case. Consequently, the integrity and identity of the seized drugs were compromised, warranting acquittal on the ground of reasonable doubt.