GR 217027; (June, 2018) (Digest)
G.R. No. 217027, June 6, 2018
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. NARCISO SUPAT Y RADOC ALIAS “ISOY”, ACCUSED-APPELLANT.
FACTS
Accused-appellant Narciso Supat was charged with illegal sale and illegal possession of dangerous drugs. The prosecution alleged that a buy-bust operation was conducted on October 8, 2005, in San Pedro, Laguna. PO3 Rivera, acting as poseur-buyer, handed a marked P100 bill to Supat in exchange for a sachet of shabu. Upon Rivera’s signal, the backup team arrested Supat, and a search yielded two more sachets from his person. The seized items were marked at the police station and later confirmed by forensic examination to be methamphetamine hydrochloride.
Supat presented a different version, claiming he was merely watching television at home when five men, including barangay tanods and police officers, entered, handcuffed him, and searched his house. He alleged that the drugs were only presented to him later. A minor corroborated his account, testifying that the men entered the house, handcuffed Supat, and later showed him plastic sachets.
ISSUE
Whether the prosecution proved the guilt of the accused beyond reasonable doubt for violations of Sections 5 and 11 of Republic Act No. 9165, particularly in establishing the integrity and evidentiary value of the seized dangerous drugs.
RULING
The Supreme Court acquitted the accused. The Court emphasized that in drug cases, the prosecution must account for each link in the chain of custody from seizure to presentation in court to ensure the identity and integrity of the corpus delicti. The Court found a broken chain of custody due to the police’s failure to comply with the witness requirement under Section 21 of RA 9165. The law requires the inventory and photography of seized items to be conducted immediately after seizure and in the presence of the accused or his representative, a representative from the media, the Department of Justice, and any elected public official.
Here, the prosecution admitted that no representatives from the media or the DOJ, and no elected official were present during the inventory. While the police claimed they attempted to contact barangay officials, they did not provide any proof of these efforts or explain why no alternative measures were taken. This unjustified non-compliance, without any showing that the integrity and evidentiary value of the items were preserved, constituted a fatal flaw. 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 guilt beyond reasonable doubt. Consequently, the integrity of the corpus delicti was compromised, warranting acquittal.