G.R. No. 229092 . February 21, 2018.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RAUL MANANSALA y MANINANG, Accused-Appellant.

FACTS

Accused-appellant Raul Manansala was charged with Illegal Sale and Illegal Possession of Dangerous Drugs under Sections 5 and 11 of Republic Act No. 9165 . The prosecution alleged that a buy-bust operation was conducted on March 7, 2009, in Calamba City. PO2 Renato Magadia Jr., acting as poseur-buyer, purchased one plastic sachet of shabu from Manansala using a marked ₱500 bill. Upon arrest, a preventive search yielded another sachet from Manansala’s pocket. The seized items were marked at the place of arrest, with an inventory conducted at the barangay hall in the presence of barangay officials. The sachets were later confirmed to contain methamphetamine hydrochloride.
Manansala denied the allegations, claiming he was forcibly taken from his home, framed, and interrogated about an unknown person. He asserted that the evidence was planted. The Regional Trial Court convicted him, a ruling affirmed by the Court of Appeals, which held that the prosecution established all elements of the crimes and that the integrity of the seized drugs was preserved despite deviations from Section 21 of RA 9165.

ISSUE

Whether the Court of Appeals erred in affirming Manansala’s conviction despite alleged non-compliance with the chain of custody requirements under Section 21, Article II of RA 9165.

RULING

The Supreme Court acquitted Manansala due to the prosecution’s failure to establish an unbroken chain of custody, which compromised the integrity and evidentiary value of the seized drugs. The Court emphasized that in drug cases, the identity of the corpus delicti must be proven with moral certainty. Section 21 requires that the physical inventory and photographing of seized items be conducted immediately after seizure in the presence of the accused or his representative, an elected public official, and representatives from the Department of Justice and the media.
Here, the police conducted the inventory only at the barangay hall, not at the place of arrest, without any justifiable ground for such transfer. Crucially, the required witnesses were absent; only barangay officials were present. The prosecution did not offer any explanation for this non-compliance, nor did it demonstrate earnest efforts to secure the presence of the insulating witnesses as mandated. The marking at the arrest site alone was insufficient to constitute compliance. The unjustified deviations from the strict procedural safeguards created reasonable doubt as to whether the items presented in court were the same ones seized from Manansala. Consequently, the integrity of the evidence was fatally compromised, warranting acquittal.