G.R. No. 219560 , July 01, 2020
JUANDOM PALENCIA Y DE ASIS, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

On April 21, 2008, a team from the National Bureau of Investigation (NBI) and the Philippine Drug Enforcement Agency (PDEA) conducted an anti-narcotics operation in Dumaguete City based on information about rampant drug sales. The team, including Special Investigator Nicanor Tagle and SPO1 Allen June Germodo, encountered petitioner Juandom Palencia y De Asis walking while looking at plastic sachets in his hand. Upon seeing the officers, Palencia attempted to flee, was restrained, and during a struggle, allegedly swallowed sachets, with one falling from his mouth. The officers recovered one heat-sealed transparent plastic sachet containing 0.01 gram of methamphetamine hydrochloride (shabu). The item was marked, inventoried on-site in the presence of a news reporter, a Department of Justice representative, and a barangay kagawad, and later confirmed positive for shabu by the crime laboratory. Palencia was charged with illegal possession of dangerous drugs under Section 11 of Republic Act No. 9165 . Palencia denied the accusation, claiming he was selling meat (bihag) when accosted, mauled, and framed, and that the drug evidence was planted. The Regional Trial Court convicted Palencia, a decision affirmed by the Court of Appeals. Palencia filed a Petition for Review on Certiorari before the Supreme Court.

ISSUE

Whether the prosecution proved beyond reasonable doubt the guilt of petitioner Juandom Palencia y De Asis for illegal possession of dangerous drugs, particularly considering the integrity and identity of the corpus delicti amidst alleged irregularities in the chain of custody and the minuscule amount of drugs seized.

RULING

The Supreme Court GRANTED the petition, REVERSED the decisions of the lower courts, and ACQUITTED Juandom Palencia y De Asis. The Court found that the prosecution failed to establish an unbroken chain of custody and to prove the identity and integrity of the seized drug beyond reasonable doubt. Critical lapses were noted: (1) The inventory and photography were not conducted immediately at the place of seizure but meters away after a delay, violating Section 21 of RA 9165. (2) The required witnesses under the law—an elected public official, a representative from the Department of Justice, and a media representative—were not present at the time of seizure and apprehension but were only called afterward, negating the purpose of witness presence to prevent planting or tampering. (3) The arresting officers did not provide justifiable grounds for these procedural deviations. (4) The minuscule amount seized (0.01 gram) warranted strict scrutiny of the buy-bust operation’s legitimacy, and the scale of the operation involving multiple agencies was disproportionate to the tiny quantity recovered, undermining the presumption of regularity in the officers’ performance. The Court emphasized that in drug cases, compliance with the chain of custody procedure is crucial, especially when the quantity of drugs is minimal, to ensure the evidence’s integrity. The presumption of innocence prevails over the presumption of regularity when procedural lapses are unexplained. Consequently, Palencia’s guilt was not proven beyond reasonable doubt.