G.R. No. 232161 . August 14, 2019.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. SHAGER LACDAN y PARTO, Accused-Appellant.

FACTS

Accused-appellant Shager Lacdan was convicted for the illegal sale of dangerous drugs under Section 5 of Republic Act No. 9165 . The prosecution evidence established that a buy-bust operation was conducted against Lacdan based on a confidential tip. PO2 Alexander Gallega acted as the poseur-buyer and purchased one plastic sachet of suspected shabu from Lacdan. Upon consummation of the sale, the backup team arrested Lacdan and recovered the marked money. The seized item was marked at the scene, and an inventory and photographing were later conducted at the police station in the presence of the accused and a media representative. The item was then submitted to the crime laboratory, where it tested positive for methamphetamine hydrochloride.
The defense presented a different version, claiming Lacdan was merely accosted by police officers looking for another person and was arrested when he could not provide information. He denied any involvement in a drug transaction. The Regional Trial Court convicted Lacdan, a decision affirmed by the Court of Appeals. Lacdan appealed to the Supreme Court, arguing a broken chain of custody over the seized drug.

ISSUE

Whether the prosecution successfully established an unbroken chain of custody over the seized dangerous drug, thereby proving the corpus delicti and warranting a conviction.

RULING

The Supreme Court reversed the conviction and acquitted Lacdan. The legal logic centered on the prosecution’s failure to comply with the chain of custody rule under Section 21 of RA 9165, which is crucial in proving the identity and integrity of the seized drug—the corpus delicti of the offense. The Court identified several critical gaps. First, there was a break in the first link of the chain: the testifying officer, PO2 Gallega, admitted he did not personally deliver the seized item to the forensic chemist but handed it to an unidentified receiving clerk at the crime laboratory. This created an unaccounted gap in the transfer. Second, the forensic chemist testified she received the specimen from this receiving clerk, not from the arresting officer, further obscuring the custody trail. These lapses constituted a failure to establish an unbroken chain, as the procedure did not ensure the item seized was the same one examined and presented in court. The presence of a media representative during inventory did not cure these fundamental breaks in the chain of custody. Without proof of the integrity of the corpus delicti, the element of the illegal sale of a dangerous drug was not proven beyond reasonable doubt. Consequently, the presumption of innocence prevailed, mandating acquittal.