G.R. No. 225210 . August 7, 2019.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. LARRY SULTAN y ALMADA, Accused-Appellant.

FACTS

Accused-appellant Larry Sultan was charged with illegal sale and possession of dangerous drugs. The prosecution alleged that in a buy-bust operation on December 6, 2012, PO2 Hechanova, acting as poseur-buyer, purchased one plastic sachet of shabu from Sultan. Upon arrest, three more sachets were allegedly recovered from Sultan’s pocket. The seized items were marked, inventoried, and photographed at a barangay hall in the presence of local officials. A forensic examination confirmed the substances were methamphetamine hydrochloride.
Sultan presented a different version. He testified he was at a hotel to book a room when he was arrested by police officers who had arrived with a friend. He denied selling or possessing any drugs and claimed the officers took his sling bag and later marked its contents, which did not include shabu. His testimony was corroborated by a companion. The Regional Trial Court and the Court of Appeals found him guilty, giving full credence to the police officers’ testimonies.

ISSUE

Whether the prosecution established the identity and integrity of the seized dangerous drugs with moral certainty, complying with the chain of custody rule under Section 21 of Republic Act No. 9165 .

RULING

The Supreme Court ACQUITTED accused-appellant Larry Sultan. The prosecution failed to establish an unbroken chain of custody, creating reasonable doubt as to the identity and integrity of the corpus delicti. The Court emphasized that in drug cases, the State must prove with moral certainty that the illegal drug presented in court is the very same substance seized from the accused.
The legal logic centers on the broken links in the custody procedure. First, the prosecution did not offer a justifiable reason for the deviation from the statutory requirement that the inventory and photographing be conducted immediately at the place of seizure or at the nearest police station. The transfer to a barangay hall, without explanation, was irregular. Second, a critical gap existed between the turnover of the seized items from the arresting officer, PO2 Hechanova, to the investigating officer, and their eventual delivery to the forensic chemist. The testimony of PO2 Hechanova did not account for who had custody of the drugs after he marked them at the barangay hall and before they were received at the crime laboratory. This missing link rendered the chain of custody incomplete. Without a properly documented and continuous chain, the possibility of evidence tampering, contamination, or substitution cannot be eliminated. Consequently, the constitutional presumption of innocence prevails, and any doubt must be resolved in favor of the accused. The failure to prove the integrity of the evidence is fatal to the prosecution’s case.