G.R. No. 224290 . June 11, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. VICENTE SIPIN Y DE CASTRO, ACCUSED-APPELLANT.

FACTS

Accused-appellant Vicente Sipin y De Castro was charged with illegal sale and illegal possession of dangerous drugs. The prosecution evidence established that a buy-bust operation was conducted based on information from a confidential asset. PO1 Richard Raagas acted as poseur-buyer and purchased one plastic sachet of shabu from Sipin for a marked P100 bill. Upon the pre-arranged signal, PO1 Arnel Diocena arrested Sipin and confiscated another sachet from his pocket. The seized items were marked at the scene, turned over to the investigating officer, and later submitted to the crime laboratory, where they tested positive for methamphetamine hydrochloride.
The defense presented a different version. Sipin testified that he was accosted by a police asset named Rolly after refusing to cooperate as an informant against a local group. He claimed he was merely invited to the municipal building for questioning but was instead framed. He denied selling or possessing any illegal drugs and alleged that the evidence was planted.

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 .

RULING

The Supreme Court acquitted the accused. The appeal was granted primarily due to the prosecution’s failure to establish an unbroken chain of custody over the seized drugs, which is crucial in proving the identity and integrity of the corpus delicti. The Court noted several gaps in the prescribed procedure under Section 21 of RA 9165. The buy-bust team did not conduct a physical inventory or take photographs of the seized items immediately after seizure and confiscation in the presence of the accused or his representative, a mandatory witness from the media or the Department of Justice, and an elected public official. The prosecution offered no justifiable reason for this lapse.
Furthermore, the Court found irregularities in the handling of the evidence. The testimony revealed that the marking of the items, while done at the scene, was not clearly shown to have been in the presence of the accused. More critically, the transfer of custody from the arresting officer to the investigator and then to the forensic chemist lacked sufficient testimony to ensure there was no opportunity for tampering or substitution. The integrity and evidentiary value of the seized items were therefore compromised. In drug cases, the State must prove not just the buy-bust operation but, with equal certainty, the identity of the dangerous drug through an unwavering chain of custody. Any failure in this chain produces reasonable doubt, which must be resolved in favor of the accused. Consequently, the Court reversed the lower courts’ decisions and ordered the immediate release of Vicente Sipin y De Castro.