G.R. No. 230228, December 13, 2017
People of the Philippines, Plaintiff-Appellee vs. Manuel Dela Rosa y Lumanog @ “Manny”, Accused-Appellant

FACTS

Accused-appellant Manuel Dela Rosa was charged with illegal sale of marijuana under Section 5, Article II of R.A. No. 9165. The prosecution alleged that a buy-bust operation was conducted on March 29 or 30, 2009, in Puerto Galera. IO1 Noe Briguel acted as poseur-buyer and purchased marijuana wrapped in dried banana leaves from Dela Rosa for marked money. Upon the pre-arranged signal, arresting officers apprehended Dela Rosa and recovered the marked money. The seized item was later marked at the PDEA office in Calapan City, 54 kilometers away, where an inventory was conducted in the presence of a barangay official and a media representative. Forensic examination confirmed the substance was marijuana.
The defense presented a starkly different version. Dela Rosa testified that he was forcibly taken from his tattoo shop by an armed man, handcuffed, and brought to the PDEA office without any buy-bust operation occurring. He claimed his arrest was due to his association with another individual previously arrested on drug charges. The Regional Trial Court convicted Dela Rosa, a ruling affirmed by the Court of Appeals.

ISSUE

Whether the prosecution proved the guilt of the accused-appellant for illegal sale of dangerous drugs beyond reasonable doubt.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED accused-appellant Manuel Dela Rosa. The Court held that the prosecution failed to establish an unbroken chain of custody over the seized marijuana, which is crucial to proving the identity and integrity of the corpus delicti.
The legal logic centers on the strict procedural requirements under Section 21 of R.A. No. 9165. The Court found multiple breaches in the chain of custody. First, the marking of the seized item was not done immediately at the place of arrest but only later at the PDEA office, without a justifiable reason for the deviation. Second, the handling of the evidence was irregular; the poseur-buyer admitted he merely placed the seized marijuana leaves in his pocket after marking, failing to use any proper evidence container. Third, there were inconsistencies regarding who received the evidence at the crime laboratory, creating doubt about its safekeeping. The prosecution did not offer any plausible explanation for these procedural lapses.
The Court emphasized that in drug cases, the State must account for each link in the chain of custody—from seizure, marking, inventory, to laboratory examination—to ensure the evidence presented in court is exactly the same substance seized from the accused. The unjustified deviations from the mandated procedure compromised the integrity and evidentiary value of the corpus delicti. Consequently, the identity of the illegal drug was not proven with moral certainty, leading to a reasonable doubt that warrants acquittal.