G.R. No. 232336. February 28, 2022.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. MARNEL VINLUAN Y LICLICAN A.K.A. “URBON,” ACCUSED-APPELLANT.

FACTS

Accused-appellant Marnel Vinluan was charged with Illegal Sale of Dangerous Drugs under Section 5, Article II of Republic Act No. 9165. The Information alleged that on December 3, 2013, in Bambang, Nueva Vizcaya, Vinluan sold dried marijuana fruiting tops contained in four heat-sealed plastic sachets to PO1 Marlon Cammayo, who acted as a poseur-buyer in a buy-bust operation. During arraignment, Vinluan pleaded not guilty.
The prosecution’s version stated that a confidential informant reported Vinluan’s illegal drug activity, leading to a planned buy-bust operation. PO1 Cammayo, as the poseur-buyer, used marked money to buy marijuana from Vinluan. After the exchange, Vinluan was apprehended. The seized items were marked at the scene in Vinluan’s presence, and an inventory was conducted in the presence of barangay kagawads Virgilio Hernandez and Norma Laguisma. Photographs were taken. The items were later delivered to the crime laboratory, where they tested positive for marijuana.
The defense version claimed that the drugs were planted. Vinluan testified that he was at home when the confidential informant and an unknown person asked him about marijuana, which he denied. Later, police officers barged into his house, handcuffed him, placed money in his hand, and presented a bag of marijuana. His stepmother, Florita Vinluan, corroborated that she saw men point a gun at Vinluan and drag him.
The Regional Trial Court found Vinluan guilty beyond reasonable doubt and sentenced him to life imprisonment and a fine. The Court of Appeals affirmed the RTC’s decision. Vinluan appealed to the Supreme Court.

ISSUE

Whether Vinluan’s conviction for Illegal Sale of Dangerous Drugs is proper.

RULING

The Supreme Court ACQUITTED accused-appellant Marnel Vinluan for failure of the prosecution to prove his guilt beyond reasonable doubt.
The Court found that while the elements of illegal sale of dangerous drugs were present, the prosecution failed to establish an unbroken chain of custody of the seized items, which compromised their integrity and evidentiary value. Specifically, the buy-bust team did not strictly comply with the witness requirements under Section 21, Article II of RA 9165. The inventory and photographing of the seized drugs were done only in the presence of barangay officials, without any representative from the media or the Department of Justice (DOJ), and there was no justifiable reason provided for this non-compliance. The prosecution also failed to recognize these lapses and to prove that the integrity of the evidence was preserved. The presumption of regularity in the performance of official duties cannot apply when there has been a clear disregard of procedural safeguards. Consequently, the identity and integrity of the corpus delicti were not proven beyond reasonable doubt, warranting Vinluan’s acquittal.