G.R. No. 230227, November 06, 2019
People of the Philippines, Plaintiff-Appellee, vs. Noel Zapanta y Lucas, Accused-Appellant.

FACTS

Accused-appellant Noel Zapanta y Lucas was charged with violations of Sections 5 (Illegal Sale) and 11 (Illegal Possession) of Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). The charges stemmed from a buy-bust operation on July 9, 2006, in Taytay, Rizal, where he was alleged to have sold 0.06 gram of shabu and was found in possession of another 0.03 gram sachet. The prosecution’s version stated that a buy-bust team conducted the operation, with a poseur-buyer purchasing the drug from accused-appellant, leading to his arrest and the recovery of the buy-bust money and the second sachet. The seized items were marked and later tested positive for methamphetamine hydrochloride. The defense claimed the incident was a frame-up, alleging that police officers entered his house, found nothing, arrested him, and demanded money from his sister. The Regional Trial Court (RTC) convicted accused-appellant, and the Court of Appeals (CA) affirmed the conviction. Accused-appellant appealed to the Supreme Court, arguing substantial gaps in the chain of custody, including the lack of immediate marking, failure to conduct inventory and photograph the seized items, and failure to present all persons who had custody of the drugs.

ISSUE

Whether the Court of Appeals correctly found accused-appellant guilty beyond reasonable doubt of illegal sale and illegal possession of dangerous drugs under RA 9165.

RULING

The Supreme Court GRANTED the appeal, REVERSED and SET ASIDE the CA Decision, and ACQUITTED accused-appellant Noel Zapanta y Lucas. The Court found that the prosecution failed to prove his guilt beyond reasonable doubt due to non-compliance with the chain of custody requirements under Section 21 of RA 9165. Specifically, the apprehending officers did not conduct a physical inventory or take photographs of the seized items, and there was no showing that the presence of a representative from the media, the Department of Justice, or any elected public official was secured to witness the inventory. Furthermore, the prosecution failed to establish an unbroken chain of custody: the first link (seizure and marking) was compromised as the marking was not done immediately at the place of arrest but only at the police station, and the testimony did not clearly detail who marked the items; the second link (turnover to investigating officer) was not established as there was no testimony on how the evidence was transferred; and the third link (turnover to forensic chemist) was not proven as the forensic chemist was not presented, and the stipulation regarding her testimony was insufficient to establish the chain. These gaps created reasonable doubt on the integrity and identity of the corpus delicti, warranting acquittal. The Court ordered the immediate release of accused-appellant unless detained for another lawful cause.