G.R. No. 220142 . January 29, 2020.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. RONALD SUATING Y SAYON ALIAS “BOK”, ACCUSED-APPELLANT.

FACTS

Accused-appellant Ronald Suating y Sayon was charged with Illegal Sale and Illegal Possession of Dangerous Drugs under Republic Act No. 9165 . The prosecution’s case, based on police testimony, alleged that a buy-bust operation was conducted on November 9, 2011, in Silay City. A confidential asset acted as poseur-buyer and purchased one stick of marijuana from Suating using marked money. The arresting officers, positioned about 10 meters away, witnessed the transaction. Upon arrest, a body search at the police station in the presence of a barangay official allegedly yielded the marked money and another stick of marijuana. The seized items were marked, inventoried, photographed, and later tested positive for marijuana. The prosecution did not present the poseur-buyer as a witness. The defense presented Suating and five community witnesses who testified that no buy-bust operation occurred, that Suating was merely buying fish when apprehended, and that only two pesos and fifty centavos were found on him during the search, claiming he was framed. The Regional Trial Court and the Court of Appeals convicted Suating, imposing life imprisonment and a fine for illegal sale, and imprisonment for illegal possession.

ISSUE

Whether the prosecution proved the guilt of the accused beyond reasonable doubt for violations of Sections 5 and 11 of Republic Act No. 9165 , particularly in establishing the integrity and identity of the seized dangerous drugs through an unbroken chain of custody.

RULING

The Supreme Court REVERSED the convictions and ACQUITTED accused-appellant Ronald Suating. The Court held that the prosecution failed to establish an unbroken chain of custody of the seized items, which is crucial in proving the identity of the corpus delicti beyond reasonable doubt. The arresting officers did not immediately mark the seized drugs at the place of arrest; instead, marking was done at the police station. The prosecution did not present testimony on the handling of the drugs from the arresting officers to the forensic chemist. The required witnesses under Section 21 of RA 9165 during the physical inventory and photographing were not properly established; the records only mentioned a barangay official, but the Court of Appeals referred to unspecified media and Department of Justice representatives without elaboration. The defense’s evidence, including testimony that only a small amount of money was found on Suating and witnesses denying the buy-bust, created reasonable doubt. The Court emphasized heightened scrutiny in cases involving miniscule amounts of drugs due to the risk of planting and tampering. The presumption of regularity in the performance of official duties cannot prevail over the constitutional presumption of innocence and the prosecution’s burden to prove guilt beyond reasonable doubt.