G.R. No. 217027 , June 6, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. NARCISO SUPAT Y RADOC alias “ISOY”, Accused-Appellant.

FACTS

This case involves a prosecution for violations of Sections 5 (Illegal Sale) and 11 (Illegal Possession) of Republic Act No. 9165 or the Comprehensive Dangerous Drugs Act of 2002. A buy-bust operation was conducted against accused-appellant Narciso Supat, resulting in his arrest and the seizure of alleged dangerous drugs. The prosecution presented evidence detailing the operation and the subsequent handling of the seized items.
However, the defense highlighted significant procedural lapses in the chain of custody. Specifically, the buy-bust team failed to comply with the witness requirement under Section 21 of RA 9165, as none of the required witnesses (a representative from the media, the Department of Justice, and an elected public official) were present during the seizure or the inventory at the police station. Furthermore, no photographs of the seized drugs were taken at the place of seizure or at the police station where the inventory was purportedly conducted.

ISSUE

Whether the prosecution successfully established the corpus delicti of the crimes charged, given the alleged breaches in the prescribed chain of custody procedures under Section 21 of RA 9165.

RULING

The Court ACQUITTED the accused-appellant. The ruling, as concurred with by Justice Peralta, is anchored on the prosecution’s failure to prove an unbroken chain of custody, which is indispensable in proving the identity and integrity of the seized dangerous drugs—the very corpus delicti of the offenses.
The legal logic is clear: strict compliance with Section 21 of RA 9165 is required to preserve the integrity of seized evidence. The law mandates the presence of insulating witnesses during inventory and photographing to prevent planting, switching, or contamination of evidence. Here, the prosecution failed to offer any justifiable reason for the complete absence of all required witnesses and the lack of required photographs. These unexplained breaches created reasonable doubt as to whether the items presented in court were the same ones seized from the accused. The Court emphasized that while the amendment under RA 10640 later reduced the witness requirement to two, the saving clause allowing non-compliance under justifiable grounds still requires the prosecution to credibly explain any deviation and prove the preserved integrity of the evidence. Since the prosecution did neither, the identity and evidentiary value of the corpus delicti were compromised, necessitating acquittal.