G.R. No. 225783 . August 20, 2018.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. CHRISTOPHER BAPTISTA y VILLA, Accused-Appellant.

FACTS

This case stemmed from a buy-bust operation conducted against accused-appellant Christopher Baptista for the illegal sale of dangerous drugs. The prosecution alleged that after a prior failed transaction, a team led by IO1 Dexter Regaspi successfully purchased one plastic sachet of shabu from Baptista for PHP 500.00 in the evening of October 3, 2011. Upon consummation of the sale, Baptista was apprehended. The inventory of the seized item was not conducted at the place of arrest due to impending rain. Instead, it was conducted at the PDEA office in the presence of only a media representative and the accused. The seized item was later subjected to laboratory examination, which confirmed the presence of methamphetamine hydrochloride.
Baptista denied the accusation, claiming he was merely on his way to meet a friend when he was forcibly apprehended by unknown men and later framed. The Regional Trial Court found him guilty of violating Section 5 of Republic Act No. 9165 , a ruling affirmed by the Court of Appeals. Both courts held that the prosecution established all elements of the crime and that the integrity of the seized drug was preserved despite procedural deviations in the inventory.

ISSUE

Whether or not the conviction of accused-appellant Christopher Baptista for Illegal Sale of Dangerous Drugs should be upheld, considering the alleged non-compliance with the chain of custody requirements under Section 21, Article II of RA 9165.

RULING

The Supreme Court acquitted Baptista. The Court emphasized that in prosecutions for illegal sale of dangerous drugs, the identity and integrity of the corpus delicti must be established beyond reasonable doubt through an unbroken chain of custody. Strict compliance with the procedure under Section 21 of RA 9165 is crucial, which mandates the immediate physical inventory and photographing of seized items in the presence of the accused or his representative, an elected public official, and a representative from the National Prosecution Service or the media.
Here, the buy-bust team committed unjustified deviations from this procedure. The inventory was conducted only in the presence of a media representative and the accused, omitting the mandatory presence of an elected public official. The prosecution failed to offer any justifiable ground for this omission, merely citing the lateness of the hour and the impending rain as reasons for moving the inventory to the office, but not for excluding the required third-party witnesses. The Court ruled that the apprehending officers did not take earnest efforts to secure the presence of such witnesses, which constitutes a fatal gap in the chain of custody. Consequently, the integrity and evidentiary value of the seized item were compromised. The presumption of regularity in the performance of official duty cannot prevail over the constitutional presumption of innocence when the procedure for safeguarding the integrity of the evidence is breached. Thus, Baptista’s guilt was not proven beyond reasonable doubt.