GR 232299; (June, 2018) (Digest)
G.R. No. 232299. June 20, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. ROBERTO ANDRADA Y CAAMPUED, ACCUSED-APPELLANT.
FACTS
The prosecution alleged that on December 21, 2011, a buy-bust operation was conducted against accused-appellant Roberto Andrada based on a tip. PO2 Allan Villanueva acted as poseur-buyer and allegedly purchased a plastic sachet of shabu from Andrada for PHP 500.00. Upon consummation of the sale, Andrada was arrested. The seized item was marked “RAC” and later confirmed by the crime laboratory to be 0.03 gram of methamphetamine hydrochloride. The defense presented a starkly different version, claiming Andrada was at home when police officers forcibly entered without a warrant, planted evidence, and falsely accused him of selling drugs after ransacking his house and taking his personal belongings.
ISSUE
Whether the prosecution proved the guilt of the accused beyond reasonable doubt for illegal sale of dangerous drugs, particularly in establishing the integrity and identity of the corpus delicti through an unbroken chain of custody.
RULING
The Supreme Court REVERSED the Court of Appeals and ACQUITTED the accused. The Court emphasized that in prosecutions for illegal sale of dangerous drugs, the identity of the drug must be established with moral certainty, requiring every link in the chain of custody—from seizure, marking, submission to the forensic laboratory, to presentation in court—to be duly accounted for. The Court found unjustified gaps in the chain of custody. The prosecution failed to establish who had immediate custody of the seized drug after PO2 Villanueva marked it and before it was delivered to the investigating officer, PO3 Uypala. There was no testimony on how the evidence was handled, stored, or transferred during this critical period. Furthermore, the prosecution did not offer any justifiable reason for this procedural lapse. The integrity of the corpus delicti was therefore compromised. The presumption of innocence prevails when the prosecution fails to overcome reasonable doubt regarding the identity of the seized drug. The weakness of the defense of denial and frame-up becomes inconsequential, as the burden of proof rests entirely on the prosecution. Consequently, Andrada’s guilt was not proven beyond reasonable doubt.