G.R. No. 229826, July 30, 2018
People of the Philippines, Plaintiff-Appellee, v. Patricia Cabrellos y Dela Cruz, Accused-Appellant.

FACTS

This case stemmed from a buy-bust operation conducted on September 22, 2005, in Ayungon, Negros Oriental. Acting on a tip, a team was formed with PO3 Allen June Germodo as the poseur-buyer. The team proceeded to accused-appellant Patricia Cabrellos’s house, where the informant introduced PO3 Germodo as a buyer. Cabrellos accepted two marked P500 bills and handed over two plastic sachets of suspected shabu. She was immediately arrested, and a search of her bag incidental to the arrest yielded seventeen more sachets. The seized items were brought to the Ayungon Police Station for initial documentation.
The police officers, however, conducted the inventory and photography of the seized items only in the presence of a barangay kagawad at the Ayungon Police Station. Subsequently, they brought Cabrellos and the items to the Dumaguete Police Station to conduct a second inventory, this time with representatives from the Department of Justice and the media present. The sachets were later confirmed by forensic analysis to contain methamphetamine hydrochloride. Cabrellos denied the charges, claiming she was merely apprehended at her home by unidentified persons looking for her husband.

ISSUE

Whether or not the prosecution established the guilt of accused-appellant Patricia Cabrellos beyond reasonable doubt for Illegal Sale and Illegal Possession of Dangerous Drugs, considering the alleged non-compliance with the chain of custody requirements under Section 21 of Republic Act No. 9165.

RULING

The Supreme Court ACQUITTED accused-appellant Patricia Cabrellos. The Court ruled that the prosecution failed to prove an unbroken chain of custody, which is crucial in establishing the identity and integrity of the seized dangerous drugs. Section 21 of RA 9165, as amended, requires that the physical inventory and photographing of seized items be conducted immediately after seizure in the presence of the accused or her representative, an elected public official, and representatives from the National Prosecution Service and the media. The law allows deviation only under justifiable grounds, provided the integrity and evidentiary value of the items are preserved.
In this case, the police conducted the initial inventory only in the presence of a barangay kagawad at the Ayungon Police Station. Their subsequent act of transporting the items to another station to secure the presence of a DOJ and a media representative for a second inventory constituted an unjustified departure from the mandated procedure. The prosecution did not offer any explanation for failing to secure all required witnesses at the place of seizure or the nearest police station, nor did it demonstrate that earnest efforts were made to comply. This procedural lapse created reasonable doubt as to whether the items presented in court were the same ones seized from Cabrellos. Consequently, the integrity and identity of the corpus delicti were compromised, warranting acquittal.