GR 229047; (April, 2018) (Digest)
G.R. No. 229047 APRIL 16, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs RAMONCITO CORNEL y ASUNCION, Accused-Appellant
FACTS
On December 15, 2013, a buy-bust operation was conducted against appellant Ramoncito Cornel in Makati City. PO1 Mark Anthony Angulo acted as poseur-buyer. The team coordinated with the PDEA. During the operation, PO1 Angulo and an informant met Cornel at a store. After a brief conversation, Cornel accepted the marked money, retrieved a plastic sachet from his pocket, and handed it to PO1 Angulo. Upon the consummated sale, PO1 Angulo gave the pre-arranged signal, and the team arrested Cornel. The marked money was recovered from him. An inventory was conducted at the barangay hall, after which the seized item was turned over to the investigator for laboratory examination, which confirmed the substance was methamphetamine hydrochloride. Cornel was charged with illegal sale of dangerous drugs under Section 5, Article II of R.A. No. 9165. He denied the accusation, claiming he was merely accosted by police officers on his way home.
ISSUE
Whether the prosecution proved the guilt of the accused beyond reasonable doubt for the illegal sale of dangerous drugs, particularly in establishing the identity and integrity of the seized drug through an unbroken chain of custody.
RULING
No. The Supreme Court reversed the Court of Appeals and acquitted the accused. The Court emphasized that in prosecutions for illegal sale of dangerous drugs, the identity of the corpus delicti must be established with moral certainty. This requires an unbroken chain of custody, with the prosecution accounting for each link from seizure to presentation in court. Crucially, the law mandates that the physical inventory and photographing of seized items be conducted immediately after seizure and in the presence of the accused or his representative, a representative from the media, the Department of Justice, and any elected public official. The records showed that while an inventory was done at the barangay hall, the prosecution failed to prove that the required insulating witnesses were present. The testimony of PO1 Angulo did not mention their presence, and no justification was offered for this procedural lapse. This failure compromised the integrity of the seized item and created reasonable doubt as to its identity as the very object seized from the accused. Consequently, the prosecution did not overcome the presumption of innocence. The acquittal is based on reasonable doubt, not on the appellant’s claim of being framed.