GR 225965; (March, 2017) (Digest)
G.R. No. 225965 . March 13, 2017.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. PUYAT MACAPUNDAG y LABAO, Accused-Appellant.
FACTS
Accused-appellant Puyat Macapundag was charged with illegal sale and illegal possession of dangerous drugs. The prosecution alleged that on March 14, 2009, a buy-bust operation was conducted in Caloocan City. PO3 George Ardedon acted as poseur-buyer and purchased one plastic sachet containing white crystalline substance from Macapundag for ₱300. Upon arrest, three more sachets were recovered from his pocket. The seized items were marked at the scene, turned over to the investigator, and subsequently examined by a forensic chemist, who confirmed the presence of ephedrine.
Macapundag denied the charges, claiming he was illegally arrested on March 12, 2009, in his home by men looking for another person. He alleged he was detained, maltreated, and a ransom was demanded for his release. He insisted the buy-bust operation did not occur and the evidence was fabricated.
ISSUE
Whether the prosecution proved the guilt of the accused beyond reasonable doubt for violations of Sections 5 and 11 of Republic Act No. 9165 , particularly in preserving the integrity and evidentiary value of the seized drugs.
RULING
The Supreme Court REVERSED the convictions and ACQUITTED Macapundag. The prosecution failed to establish an unbroken chain of custody, which is crucial in proving the identity of the corpus delicti. The Court noted glaring breaches in the procedure mandated under Section 21 of RA 9165. The buy-bust team did not conduct a physical inventory or photograph the seized items immediately after seizure and arrest. The prosecution offered no justifiable reason for this omission.
Furthermore, the evidence did not show who had custody of the drugs between their turnover at the police station and their delivery to the crime laboratory, creating a significant gap in the chain. The testimony of the forensic chemist did not remedy this break, as she could only account for the integrity of the items upon receipt at the lab. The presumption of regularity in the performance of official duty cannot prevail over the constitutional presumption of innocence and cannot substitute for the prosecution’s burden to prove guilt beyond reasonable doubt. The procedural lapses compromised the identity of the seized drugs, warranting acquittal.