G.R. No. 223515 . June 25, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. FRANCIS TABOY Y AQUINO, ACCUSED-APPELLANT.

FACTS

Accused-appellant Francis Taboy was charged with illegal sale of shabu, illegal possession of drug paraphernalia, and illegal use of dangerous drugs. The prosecution alleged that on January 5, 2012, a buy-bust operation was conducted in Camiling, Tarlac. PO2 Jojie Navero acted as poseur-buyer and transacted with Taboy, resulting in the sale of one plastic sachet of shabu. Upon arrest, drug paraphernalia were recovered from Taboy. The seized item was marked at the barangay hall in the presence of barangay officials and later confirmed by forensic examination to be methamphetamine hydrochloride. A drug test on Taboy also yielded a positive result.
The defense presented a different version, claiming Taboy was arbitrarily arrested without a buy-bust. He alleged that after a drinking session, he was accosted by police officers, forcibly taken, and later framed by planting evidence. The Regional Trial Court found him guilty on all charges, a decision affirmed by the Court of Appeals. Taboy appealed to the Supreme Court, questioning the validity of his arrest and the integrity of the seized drugs.

ISSUE

The core issue is whether the prosecution successfully proved the guilt of the accused-appellant beyond reasonable doubt for violations of Sections 5, 12, and 15 of Republic Act No. 9165 , particularly in establishing the identity and integrity of the corpus delicti in the face of alleged procedural lapses in the chain of custody.

RULING

The Supreme Court acquitted accused-appellant. The Court emphasized that in drug cases, the prosecution must establish an unbroken chain of custody to prove the identity of the prohibited drug with moral certainty. The Court found a critical break in this chain. While the marking of the seized sachet was done at the barangay hall, the required witnesses under Section 21 of RA 9165—an elected public official and a representative from the Department of Justice or the media—were not present. Only a barangay captain was present, and there was no showing that a DOJ or media representative was ever contacted or attempted to be secured. The prosecution offered no justifiable reason for this non-compliance.
The Court ruled that the unjustified failure to adhere to the witness requirement compromised the integrity of the evidence. This procedural lapse created reasonable doubt as to whether the item presented in court was the same one seized from the accused. Consequently, the corpus delicti for the sale and possession charges was not established with the required certainty. Regarding the charge for drug use under Section 15, the Court also acquitted, noting that a positive drug test result alone, without evidence of actual use apprehended in the act, is insufficient for conviction under the prevailing jurisprudence at the time. The presumption of innocence prevailed.