G.R. No. 227309 , August 16, 2017
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JOCELYN CARLIT y GAWAT, Accused-Appellant.

FACTS

Accused-appellant Jocelyn Carlit was convicted by the Regional Trial Court for the illegal sale of dangerous drugs under Section 5 of Republic Act No. 9165 . The prosecution evidence established that a buy-bust operation was conducted against Carlit in Dagupan City on February 26, 2011. P03 Christian Carvajal acted as the poseur-buyer and successfully purchased a sachet of shabu from Carlit in exchange for marked money. Upon consummation of the sale, Carlit was arrested. The seized item was marked at the police station and later brought by P03 Carvajal himself to the crime laboratory, where Forensic Chemist PSI Myrna Malojo Todefio examined it and found it positive for methamphetamine hydrochloride. The prosecution presented only these two witnesses.
Carlit denied the accusation, claiming she was unlawfully arrested while on her way to her mother’s house. She testified that police officers handcuffed her without cause after confirming her identity. Her testimony was corroborated by a witness, Maria Fe De Vera. The RTC found the prosecution’s version credible and convicted Carlit. The Court of Appeals affirmed the conviction, giving weight to the testimony of the poseur-buyer and the forensic chemist.

ISSUE

Whether the prosecution successfully established an unbroken chain of custody of the seized dangerous drug, thereby proving Carlit’s guilt beyond reasonable doubt.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED Carlit. The Court held that the prosecution failed to establish every link in the chain of custody with the required moral certainty, creating reasonable doubt as to her guilt. While the testimonies of the poseur-buyer and the forensic chemist accounted for the seizure, marking, and examination of the drug, a critical gap existed in the chain. The prosecution did not present the testimony of the evidence custodian, P02 Manuel, to whom the forensic chemist stated she had turned over the specimen after examination. This failure left the custody of the evidence from the time of laboratory examination until its presentation in court unaccounted for, breaking the chain.
Furthermore, the buy-bust team did not comply with the witness requirements under Section 21 of RA 9165, as amended. The law mandates that the inventory and photographing of seized items be conducted immediately after seizure and in the presence of the accused or her representative, a representative from the media, the Department of Justice, and any elected public official. The prosecution admitted that no media representative was present during the preparation of the confiscation receipt, and it offered no justifiable reason for this non-compliance. The integrity and evidentiary value of the corpus delicti were therefore compromised. In prosecutions for illegal drug sale, the identity of the dangerous drug must be established with unwavering exactitude. Any lapse in the chain of custody, without valid explanation, warrants acquittal. Consequently, Carlit’s guilt was not proven beyond reasonable doubt.