G.R. No. 230615. March 04, 2019
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. HERMOGENES MANAGAT, JR. Y DE LEON AND DINDO CARACUEL Y SULIT, ACCUSED-APPELLANTS.

FACTS

The accused-appellants were charged with illegal sale of marijuana under Section 5, Article II of Republic Act No. 9165. The prosecution alleged that on February 1, 2007, in Los Baños, Laguna, a buy-bust operation was conducted based on information from a civilian asset. The asset approached appellant Caracuel, handed marked money, which was then given to appellant Managat. Managat, in turn, handed a folded newspaper containing marijuana to Caracuel, who passed it to the asset. Upon the pre-arranged signal, the police team arrested the appellants. The seized item was marked at the scene and later submitted for laboratory examination, which confirmed it was marijuana.
The defense presented a different version, claiming they were arbitrarily arrested. Managat testified he was at home when police searched his house and arrested him. Caracuel claimed he was collecting payments for his business when he was suddenly apprehended. Both denied any involvement in a drug transaction and alleged they were forced to admit the crime at the police station. The Regional Trial Court found them guilty, a decision affirmed with modification by the Court of Appeals.

ISSUE

Whether the guilt of the accused-appellants for the illegal sale of dangerous drugs was proven beyond reasonable doubt, particularly regarding the integrity and identity of the corpus delicti.

RULING

The Supreme Court REVERSED the Court of Appeals’ decision and ACQUITTED the accused-appellants. The Court emphasized that in prosecutions for illegal sale of dangerous drugs, the identity of the drug must be established with moral certainty. It is imperative to account for each link in the chain of custody from seizure to presentation in court. The prosecution failed to establish an unbroken chain. Testimonies revealed that after the seizure and marking at the scene, PO2 Ortega turned over the item to investigators PO3 Gibe and PO1 Tamayo at the police station. However, these investigators were never presented in court to testify on how they handled and safeguarded the evidence before it was delivered to the forensic chemist. This gap created reasonable doubt as to whether the item examined was the same one seized from the appellants. The stipulated testimony of the forensic chemist only confirmed that the item she received tested positive, but did not cure the missing link in the custody process. The Court ruled that the prosecution’s non-compliance with the chain of custody procedure, without any justifiable reason, compromised the integrity of the evidence. Consequently, the identity of the corpus delicti was not preserved, warranting acquittal based on reasonable doubt.