GR 224297; (February, 2019) (Digest)
G.R. No. 224297 February 13, 2019
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. EDGARDO ROYOL y ASICO, Accused-Appellant
FACTS
Accused-appellant Edgardo Royol, a garbage collector, was charged with the illegal sale of dangerous drugs under Section 5 of Republic Act No. 9165 . The prosecution alleged that on November 27, 2007, a buy-bust operation was conducted in Bamban, Tarlac, where PO2 Mark Anthony Baquiran acted as poseur-buyer. Royol was accused of selling half a brick of dried marijuana fruiting tops weighing 500.28 grams in exchange for two marked P500 bills. Upon the consummation of the sale, Royol was arrested. The seized item was later marked at the police station and subsequently brought to the crime laboratory, where it tested positive for marijuana. Royol denied the accusation, claiming he was merely collecting garbage when he was apprehended by men who handcuffed him, took his money, and falsely implicated him.
The Regional Trial Court convicted Royol of the crime charged and sentenced him to life imprisonment and a fine of P500,000.00. The Court of Appeals affirmed this decision in toto. Royol appealed to the Supreme Court, arguing the prosecution’s failure to establish an unbroken chain of custody over the seized drugs.
ISSUE
Whether or not the prosecution established accused-appellant Edgardo Royol’s guilt beyond reasonable doubt for the illegal sale of dangerous drugs.
RULING
No. The Supreme Court reversed the lower courts’ decisions and acquitted Royol due to the prosecution’s complete and utter noncompliance with the chain of custody requirements under Section 21 of RA 9165. The Court emphasized that in drug-related cases, the identity and integrity of the corpus delicti must be established with moral certainty. The law mandates specific procedural safeguards—including the immediate physical inventory and photographing of seized items in the presence of the accused or his representative, an elected public official, and representatives from the Department of Justice and the media—to prevent tampering or switching of evidence.
The records revealed a broken chain of custody. The prosecution failed to offer any justifiable reason for its nonobservance of the mandatory witness requirement during the inventory. No elected public official or media representative was present. The prosecution merely presumed regularity in the performance of official duties, which is insufficient to prove an unbroken chain. The apprehending officers did not even attempt to explain their deviation from the procedure. Consequently, the integrity and evidentiary value of the seized item were compromised. The Court ruled that the presumption of regularity cannot prevail over the constitutional presumption of innocence and the prosecution’s burden to prove guilt beyond reasonable doubt. The unjustified breaches of procedure warranted acquittal.