G.R. No. 222559, June 6, 2018
People of the Philippines, Plaintiff-Appellee, vs. Jennifer Ga-a y Coronado, Accused, Aquila “Payat” Adobar, Accused-Appellant.

FACTS

Accused-appellant Aquila Adobar was charged with illegal sale of dangerous drugs under Section 5, Article II of R.A. 9165. The prosecution alleged that on May 9, 2011, a buy-bust team was formed, with IO1 Naomie Siglos acting as poseur-buyer. She was introduced to Adobar by a confidential informant at his residence. Adobar asked how much shabu she wanted, and upon receiving a marked P500 bill, he went inside his house and returned with a heat-sealed plastic sachet containing white crystalline substance. After the transaction, Siglos gave the pre-arranged signal, and the team rushed in. Adobar escaped, but his live-in partner, Jennifer Ga-a, was found inside with seventeen other sachets of suspected shabu.
The defense presented a different version, claiming the incident was a frame-up. Adobar testified that on the said date, armed men forcibly entered his home, handcuffed him and Ga-a, and planted the drugs. He alleged the officers demanded money in exchange for their release. The Regional Trial Court found Adobar guilty, a decision affirmed by the Court of Appeals, prompting this appeal.

ISSUE

Whether the prosecution proved Adobar’s guilt for illegal sale of dangerous drugs beyond reasonable doubt, particularly in establishing the identity and integrity of the corpus delicti in light of alleged procedural lapses in the chain of custody.

RULING

The Supreme Court ACQUITTED accused-appellant Adobar. The prosecution failed to establish an unbroken chain of custody, which is crucial in proving the identity of the illegal drug, the corpus delicti of the offense. The Court found unjustified deviations from the mandatory procedure under Section 21, Article II of R.A. 9165. The required witnesses—an elected public official, a representative from the Department of Justice, and a media representative—were not present during the immediate physical inventory and photographing of the seized item at the place of arrest. The inventory was conducted at the police station, and the only witness present was the Punong Barangay. The prosecution offered no justifiable ground for this non-compliance.
The law requires the insulating presence of these witnesses to prevent planting, switching, or contamination of evidence. Their absence, without a credible explanation, casts doubt on the integrity of the seized drug. The Court emphasized that while the procedural requirements may be excused under justifiable grounds, the prosecution bears the burden of proving such justification and that the integrity of the evidence was preserved. Here, the prosecution failed to discharge this burden. Consequently, the identity of the corpus delicti was compromised, creating reasonable doubt as to Adobar’s guilt. An acquittal is therefore warranted.