G.R. No. 224223 , November 20, 2019
People of the Philippines, Plaintiff-Appellee, vs. Norman Angeles y Miranda, Accused-Appellant.

FACTS

An Information charged Norman Angeles y Miranda (appellant) with Illegal Sale of Dangerous Drugs under Section 5, Article II of Republic Act No. 9165 . The prosecution alleged that on October 26, 2012, in Binangonan, Rizal, the appellant sold 0.05 gram of methamphetamine hydrochloride (shabu) to PO1 Raul G. Paran for Php 200.00 during a buy-bust operation. The police team, acting on a tip from a confidential informant (CI), conducted the operation where PO1 Paran and the CI bought the drugs from the appellant. Upon the pre-arranged signal, the appellant was arrested, the marked money was confiscated, and the seized plastic sachet was recovered from the CI, marked “NOR,” and subjected to inventory in the presence of a media representative. The forensic examination confirmed the substance was shabu. The appellant denied the allegations, claiming he was arbitrarily arrested at home without any buy-bust operation taking place. The Regional Trial Court (RTC) found him guilty beyond reasonable doubt, sentencing him to life imprisonment and a fine. The Court of Appeals (CA) affirmed the RTC decision with modification regarding parole eligibility.

ISSUE

Whether the prosecution proved the appellant’s guilt for illegal sale of dangerous drugs beyond reasonable doubt, particularly in establishing the corpus delicti and preserving the integrity and evidentiary value of the seized drugs through strict compliance with the chain of custody requirements under Section 21, Article II of RA 9165.

RULING

The Supreme Court GRANTED the appeal and ACQUITTED the appellant. The Court found that the prosecution failed to establish an unbroken chain of custody, thereby compromising the integrity and evidentiary value of the seized drugs. Specifically, the apprehending officers did not comply with the witness requirements under Section 21, Article II of RA 9165, as amended. The inventory and photographing of the seized item were conducted only in the presence of a media representative, without the required elected public official and a representative from the National Prosecution Service or the Department of Justice. The prosecution offered no justifiable reason for this non-compliance. Given the minuscule amount of shabu involved (0.05 gram), which necessitates a higher level of scrutiny and stricter compliance with procedural safeguards, the lapse in procedure created reasonable doubt as to the identity of the corpus delicti. Consequently, the appellant’s guilt was not proven beyond reasonable doubt.