G.R. No. 231796 , August 24, 2020
People of the Philippines, Plaintiff-Appellee, v. Johnny Arellaga y Sabado, Accused-Appellant.

FACTS

Accused-appellant Johnny Arellaga was charged with illegal sale and possession of dangerous drugs under Sections 5 and 11 of Republic Act No. 9165 . The prosecution alleged that on May 23, 2013, a buy-bust operation was conducted where a police officer, acting as a poseur-buyer, purchased one sachet of shabu from Arellaga. Upon arrest, three additional sachets were allegedly recovered from him. The police officers marked the seized items, conducted an inventory, and later submitted them for laboratory examination, which yielded positive for methamphetamine hydrochloride.
The defense presented a starkly different version. Arellaga claimed he was at home with his stepdaughter when police officers forcibly entered, conducted a warrantless search, and arrested him. He alleged that the officers stole personal items and later physically coerced him at the station. His stepdaughter corroborated this account, testifying to the illegal entry and search, and the subsequent loss of property.

ISSUE

Whether the prosecution proved the guilt of the accused beyond reasonable doubt for the crimes of illegal sale and possession of dangerous drugs.

RULING

The Supreme Court acquitted the accused. The ruling hinged on the prosecution’s failure to establish an unbroken chain of custody of the seized drugs, which compromised the integrity of the corpus delicti. The Court emphasized that in drug cases, the identity of the dangerous drug must be established with moral certainty, and this is safeguarded by strict compliance with the chain of custody rule under Section 21, Article II of RA 9165.
The law requires the inventory and photography of seized items to be conducted immediately after seizure and in the presence of the accused or his representative, a representative from the media, the Department of Justice, and any elected public official. The records showed that the inventory was witnessed only by a barangay official. The prosecution offered no justifiable reason for the absence of the other required witnesses. This unexplained deviation from the mandatory procedure created reasonable doubt as to whether the items presented in court were the same ones seized from the accused. The possibility of evidence planting or contamination could not be eliminated. Consequently, the integrity and evidentiary value of the seized drugs were fatally compromised, warranting acquittal.