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

This case involves an appeal from a conviction for violation of Section 5, Article II of R.A. No. 9165 (Comprehensive Dangerous Drugs Act of 2002). The prosecution’s evidence stemmed from a buy-bust operation where accused-appellant Aquila Adobar was apprehended. Following the seizure of the alleged dangerous drugs, the apprehending officers conducted a physical inventory and photographing of the items.
The inventory was witnessed by a barangay captain and a media representative. Notably absent was a required witness from the Department of Justice (DOJ). The prosecution did not provide any justifiable reason for this absence. The case proceeded to trial, resulting in Adobar’s conviction, which he then appealed.

ISSUE

Whether the prosecution successfully established the integrity and evidentiary value of the seized dangerous drugs despite non-compliance with the witness requirements under Section 21 of R.A. No. 9165 .

RULING

The Court acquitted accused-appellant Adobar. The ruling, as concurred with by Justice Peralta, emphasized the mandatory nature of the procedural safeguards under Section 21 of R.A. No. 9165 . The law requires the presence of three witnesses during inventory: an elected public official, a media representative, and a DOJ representative. The buy-bust team failed to secure a DOJ witness without offering any justifiable ground for this lapse.
Justice Peralta’s concurring opinion elaborated on the legal framework, noting that while R.A. No. 10640 later amended Section 21 to require only two witnesses, the original law governed this case. The absence of a required witness, unexplained by justifiable grounds, constitutes a fatal procedural gap. This gap breaches the chain of custody, as it creates doubt about whether the items presented in court are the same ones seized from the accused. The integrity and evidentiary value of the corpus delicti were therefore not preserved. In drug cases, strict compliance with the chain of custody rule is paramount, and the prosecution bears the burden of proving compliance or justifying any deviation. Failure to do so warrants acquittal.