G.R. No. 219829 January 18, 2017
People of the Philippines, Plaintiff-Appellee vs. Monir Jaafar y Tambuyong, Accused-Appellant

FACTS

Accused-appellant Monir Jaafar was charged with illegal sale of dangerous drugs under Republic Act No. 9165 . The prosecution alleged that a buy-bust operation was conducted based on a tip that Jaafar was selling shabu. PO1 Look acted as poseur-buyer and, upon meeting Jaafar at his house, handed him a marked 500-peso bill. Jaafar then called for his co-accused, Ahmad Gani, who handed him a sachet, which Jaafar subsequently gave to PO1 Look. Upon the pre-arranged signal, the team arrested Jaafar after a brief chase. The seized sachet was marked by PO1 Look and later tested positive for methamphetamine hydrochloride.
Jaafar presented a different version, claiming he was merely apprehended by six persons while walking home from an internet cafe, with no buy-bust occurring. The Regional Trial Court convicted Jaafar, finding the prosecution’s version credible and the elements of the crime established, while acquitting Gani due to insufficient evidence. The Court of Appeals affirmed the conviction. Jaafar appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt and violated the chain of custody rule.

ISSUE

Whether the Court of Appeals erred in affirming Jaafar’s conviction despite alleged irregularities in the chain of custody of the seized drugs.

RULING

The Supreme Court reversed the conviction and acquitted Jaafar. The legal logic centered on the prosecution’s failure to establish an unbroken chain of custody, which is crucial in drug cases to prove the integrity and identity of the corpus delicti. The Court noted that while the buy-bust team initially coordinated with the Philippine Drug Enforcement Agency (PDEA), the required witnesses during the inventory and photography of the seized items were not present. The law mandates that the inventory be conducted immediately after seizure in the presence of the accused or his representative, a representative from the media and the Department of Justice, and any elected public official.
The prosecution offered no justifiable reason for this absence. The police officers merely testified that the inventory was done at the police station without these witnesses. This constituted a substantial gap in the chain of custody. 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, especially when there is a clear lapse in procedure. The integrity of the evidence was therefore compromised, creating reasonable doubt as to whether the sachet presented in court was the same one allegedly seized from Jaafar. Consequently, his guilt was not proven to the required moral certainty.