G.R. No. 229787. June 20, 2018.
Ricky Anyayahan y Taronas, Petitioner, v. People of the Philippines, Respondent.

FACTS

Petitioner Ricky Anyayahan was charged with Illegal Sale and Illegal Possession of Dangerous Drugs. The prosecution alleged that a buy-bust operation was conducted where a poseur-buyer purchased one sachet of shabu from Anyayahan, who was found in possession of another sachet. The seized items were marked, photographed, and inventoried at the place of arrest in the presence of a barangay kagawad and a media representative. The items tested positive for methamphetamine hydrochloride.
Anyayahan denied the charges, claiming he was arbitrarily arrested while walking with his partner. The Regional Trial Court (RTC) acquitted him of Illegal Sale due to the prosecution’s failure to prove the element of consideration, as the handling of the buy-bust money was unclear and the marked money was not properly presented. However, the RTC convicted him for two counts of Illegal Possession for the sachet sold and the sachet found in his pocket. The Court of Appeals affirmed the conviction.

ISSUE

Whether the Court of Appeals erred in affirming Anyayahan’s conviction for Illegal Possession of Dangerous Drugs.

RULING

The Supreme Court reversed the conviction and acquitted Anyayahan. The acquittal for Illegal Sale removed the predicate act from which the first possession charge (the sachet allegedly sold) was derived. Consequently, there was no legal basis to sustain a conviction for possession based on that same sachet. The Court clarified that a person cannot be convicted for illegal possession of the very object of an illegal sale for which he was acquitted, as the offenses are distinct and the elements for possession were not independently proven for that item.
Regarding the second sachet (allegedly found in his pocket), the Court ruled that the prosecution failed to establish an unbroken chain of custody. The arresting officers did not immediately conduct the physical inventory and photography at the place of arrest as required by law. The testimony revealed a significant gap, as the items were first brought to the police station before the inventory was signed by the required witnesses. This unjustified deviation from the mandated procedure compromised the integrity and evidentiary value of the seized drug. The prosecution’s failure to provide justifiable grounds for this non-compliance and to prove the identity of the corpus delicti beyond reasonable doubt warranted acquittal.