G.R. No. 215344 June 10, 2019
People of the Philippines, Plaintiff-Appellee vs. Evangeline Garcia y Suing, Accused-Appellant

FACTS

Accused-appellant Evangeline Garcia was charged with violating Section 5, Article II of R.A. 9165 for allegedly selling one plastic sachet of methamphetamine hydrochloride to a poseur-buyer for P500.00 on January 9, 2009. The prosecution evidence established that a buy-bust team was formed after a confidential informant reported Garcia’s illegal drug activity. IO1 Lanibelle Ancheta acted as the poseur-buyer, marked the buy-bust money, and, upon meeting Garcia, successfully purchased the sachet. Garcia was immediately arrested, and an inventory of the seized item was conducted at the scene in the presence of a media representative and a barangay official. The sachet tested positive for methamphetamine hydrochloride.
Garcia denied the accusation, claiming she was sleeping when armed PDEA agents barged into her house and searched her belongings without a warrant. She asserted that no buy-bust operation occurred and that the evidence was planted. The Regional Trial Court found her guilty, a decision affirmed by the Court of Appeals. Garcia appealed to the Supreme Court, arguing the prosecution failed to prove her guilt beyond reasonable doubt and to establish an unbroken chain of custody over the seized drug.

ISSUE

Whether the prosecution successfully established the identity and integrity of the seized dangerous drug, thereby proving Garcia’s guilt beyond reasonable doubt for illegal sale of dangerous drugs.

RULING

The Supreme Court acquitted Garcia. The Court emphasized that in drug-related prosecutions, the identity of the corpus delicti must be established with moral certainty through an unbroken chain of custody. The Court found a critical gap in the chain of custody. While the marking and inventory at the scene were witnessed, the prosecution failed to account for the handling of the evidence after it was brought to the crime laboratory. There was no testimony from the officer who received the evidence at the laboratory, nor from the forensic chemist who conducted the examination, to confirm the condition of the item when received and to detail the transfer from the investigating officer to the examiner. This break in the chain created reasonable doubt as to whether the item presented in court was the same one seized from Garcia. The presumption of regularity in the performance of official duty cannot prevail over the constitutional presumption of innocence and the prosecution’s burden to prove every element of the crime, including the integrity of the evidence. Consequently, the failure to prove an unbroken chain of custody warranted acquittal.