G.R. No. 217668 February 20, 2019
People of the Philippines, Plaintiff-Appellee vs. Benjie Caranto y Austria, Accused-Appellant

FACTS

Accused-appellant Benjie Caranto was charged with illegal sale of dangerous drugs under Section 5, Article II of Republic Act No. 9165 . The prosecution alleged that on August 4, 2010, a buy-bust operation was conducted in Baguio City where PO2 Christian Boado, acting as poseur-buyer, purchased one heat-sealed plastic sachet containing 0.07 gram of methamphetamine hydrochloride from Caranto for PHP 1,000. Upon consummation of the sale, Caranto was arrested. The seized item was marked at the site, and an inventory was conducted at the police station in the presence of Caranto, a DOJ prosecutor, a barangay official, and a media representative. The sachet was then forwarded to the crime laboratory, where it tested positive for the presence of shabu.
Caranto denied the accusation, claiming he was merely a taxi driver flagged down by the police. He asserted that the buy-bust was a frame-up and that the procedural requirements under Section 21 of RA 9165 regarding the chain of custody of the seized drugs were not complied with. The Regional Trial Court convicted him, a decision affirmed by the Court of Appeals, prompting this appeal.

ISSUE

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

RULING

The Supreme Court ACQUITTED accused-appellant Benjie Caranto. The Court emphasized that in drug-related prosecutions, the State must prove not only the occurrence of the sale but, with equal importance, the unbroken chain of custody of the seized drug to ensure its integrity from seizure to presentation in court. The Court found a critical gap in the chain of custody. While the inventory was conducted at the police station, the prosecution failed to establish that the marking of the seized item—a crucial first step in the custodial chain—was done immediately after seizure at the place of arrest. The testimonies of the arresting officers were inconsistent and unclear on this point, with one stating the marking was done at the site and another suggesting it was done later at the station. This ambiguity creates reasonable doubt on whether the item presented in court was the very same one seized from Caranto. The Court ruled that the prosecution’s failure to account for who had custody of the drug between its alleged marking and the station inventory, and to justify the deviation from the mandated procedure of immediate marking, fatally compromised the integrity of the evidence. Consequently, Caranto’s guilt was not proven beyond reasonable doubt.