G.R. No. 218107, September 09, 2019.
People of the Philippines, Plaintiff-Appellee, vs. Jose Jamillo Quilatan y Dela Cruz, Accused-Appellant.

FACTS

Accused-appellant Jose Jamillo Quilatan y Dela Cruz was charged with violations of Sections 5 (illegal sale) and 11 (illegal possession) of Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). The prosecution’s version states that on June 15, 2009, a buy-bust team was formed based on a tip from an informant. PO2 Elbert Ocampo acted as poseur-buyer and purchased one plastic sachet of suspected shabu from Quilatan for PHP 500.00. Upon the consummation of the sale, Quilatan was arrested, and another plastic sachet was recovered from his right hand. The seized items were marked and inventoried at the Barangay Hall of San Dionisio, Parañaque City, in the presence of Quilatan and a Barangay Desk Officer. Laboratory examination confirmed the substances were methamphetamine hydrochloride. Quilatan denied the charges, claiming he was arrested for a traffic violation (driving without a helmet) and that the police officers framed him by planting evidence. He also alleged that during the inventory at the Barangay Hall, no elected public official, media representative, or DOJ representative was present.

ISSUE

Whether the prosecution proved Quilatan’s guilt for violation of Sections 5 and 11 of RA 9165 beyond reasonable doubt.

RULING

No. The Supreme Court reversed the decisions of the lower courts and acquitted Quilatan. The prosecution failed to establish an unbroken chain of custody due to unjustified non-compliance with the witness requirements under Section 21 of RA 9165. The law requires the physical inventory and photographing of seized items to be conducted in the presence of the accused or his representative, and crucially, a representative from the media, the Department of Justice (DOJ), and any elected public official. The prosecution admitted that only a barangay desk officer was present during the inventory, and no representative from the media or the DOJ was there. The prosecution offered no justifiable grounds for this non-compliance. The saving clause allowing non-compliance under justifiable grounds, provided the integrity and evidentiary value of the seized items are preserved, cannot be invoked when the prosecution does not even acknowledge the lapse or attempt to provide a justification. The unjustified failure to comply with the mandatory procedure created reasonable doubt as to the identity and integrity of the corpus delicti. Consequently, Quilatan’s guilt was not proven beyond reasonable doubt.