GR 228825; (July, 2020) (Digest)
G.R. No. 228825 , July 28, 2020
People of the Philippines, Plaintiff-Appellee, vs. Eduardo Manansala y Pabalan a.k.a. “Eddie,” Accused-Appellant.
FACTS
Accused-appellant Eduardo Manansala was charged with violating Section 5 of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) for selling marijuana. A buy-bust operation was conducted on July 21, 2008, in Angeles City. A confidential informant acted as poseur-buyer, accompanied by SPO1 Nachor. The accused-appellant allegedly sold two plastic sachets of marijuana fruiting tops to the informant in exchange for marked money. The backup team arrested him. The seized items were inventoried at the police station in the presence of the accused-appellant and later tested positive for marijuana. The accused-appellant denied the charges, claiming he was forcibly taken from his home, searched, and framed. The Regional Trial Court convicted him, a decision affirmed by the Court of Appeals. The defense centered on the police’s non-compliance with Section 21 of R.A. No. 9165 , specifically the absence of required witnesses (a DOJ representative, media representative, and elected public official) during the inventory, and the non-presentation of the confidential informant.
ISSUE
Whether the accused-appellant is guilty beyond reasonable doubt of violating Section 5, Article II of R.A. No. 9165 , considering the alleged lapses in the chain of custody procedure under Section 21.
RULING
The Supreme Court REVERSED and SET ASIDE the decision of the Court of Appeals and ACQUITTED the accused-appellant. The Court ruled that the prosecution failed to prove an unbroken chain of custody due to the police officers’ unjustified non-compliance with the mandatory witness requirement under Section 21 of R.A. No. 9165 . The inventory was conducted only in the presence of the accused-appellant, without the required representatives from the Department of Justice, the media, or any elected public official. The prosecution did not offer any justifiable reason for this lapse, nor did it prove that the integrity and evidentiary value of the seized items were preserved despite the procedural deviation. The presumption of regularity in the performance of official duty cannot apply when there was a clear disregard of the prescribed procedure. Consequently, the identity and integrity of the corpus delicti were compromised, warranting acquittal on reasonable doubt.