G.R. No. 231361 , July 3, 2019
People of the Philippines, Plaintiff-Appellee vs. Carol Alcantara y Mapata and Joselito Cruz y De Guzman, Accused-Appellants

FACTS

Accused-appellants Alcantara and Cruz, along with others, were charged with illegal sale and possession of dangerous drugs. The prosecution’s case stemmed from a buy-bust operation on October 2, 2003. A police poseur-buyer was introduced to a seller, Jonathan Manuel, who directed them to a house in San Mateo, Rizal. There, the poseur-buyer transacted with accused Ressurreccion, using marked money to purchase three sachets of shabu. Upon the consummation of the sale, the police team arrested the individuals inside the house, including Alcantara and Cruz, and seized additional drugs and paraphernalia from a table.
The defense presented a different version, claiming the accused were merely having a drinking session when police officers forcibly entered, arrested them, and planted the evidence. The Regional Trial Court convicted the accused-appellants, a decision affirmed by the Court of Appeals. The appellants elevated the case to the Supreme Court, arguing the prosecution failed to establish the identity and integrity of the seized drugs due to non-compliance with the chain of custody requirements under Section 21 of Republic Act No. 9165 .

ISSUE

Whether the guilt of the accused-appellants was proven beyond reasonable doubt, considering the alleged breaches in the chain of custody of the seized dangerous drugs.

RULING

The Supreme Court acquitted the accused-appellants. The legal logic centered on the imperative of establishing an unbroken chain of custody to prove the identity and integrity of the corpus delicti in drug cases. The Court found that the apprehending team committed unjustified deviations from the mandatory procedure under Section 21, Article II of RA 9165. The inventory and photography of the seized items were not conducted immediately at the place of seizure. Instead, the evidence was brought to the police station, where the inventory was done only in the presence of a barangay official, with no representative from the media or the Department of Justice, and without the accused or their counsel. The prosecution offered no explanation for these lapses, failing to prove that earnest efforts were made to secure the presence of the required witnesses. The Court emphasized that while strict compliance may not always be possible, the prosecution must justify any deviation. The unjustified non-compliance created reasonable doubt as to whether the drugs presented in court were the same ones seized from the accused. Consequently, the integrity and evidentiary value of the corpus delicti were compromised, warranting acquittal.