G.R. No. 232357 , November 28, 2018
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. EDWIN CABEZUDO Y RIEZA, ACCUSED-APPELLANT.

FACTS

The prosecution’s evidence established that a buy-bust operation was conducted against accused-appellant Edwin Cabezudo based on information from a confidential informant. The team, with SI2 Erwin Magpantay as poseur-buyer, transacted with Cabezudo in Barangay Palanas, Paracale, Camarines Norte. Cabezudo handed over a plastic sachet of suspected shabu in exchange for PHP 500.00. Upon the pre-arranged signal, the team arrested him. The seized item was marked at the scene, photographed, and an inventory was later conducted at the barangay hall in the presence of the barangay chairman and representatives from the DOJ and media. The substance tested positive for methamphetamine hydrochloride.
The defense presented a starkly different narrative. Cabezudo testified that he was in Paracale to redeem his impounded motorcycle. Upon alighting from a tricycle near a cockpit, he was suddenly accosted by men who handcuffed him, planted evidence, and confiscated PHP 18,000.00 from him. He alleged that the arresting officer later demanded money for his release. He denied any involvement in the sale of illegal drugs.

ISSUE

Whether the prosecution successfully proved the guilt of the accused-appellant for illegal sale of dangerous drugs beyond reasonable doubt, particularly in establishing the integrity and evidentiary value of the seized item through strict compliance with the chain of custody rule under Section 21 of Republic Act No. 9165 .

RULING

The Supreme Court ACQUITTED accused-appellant Edwin Cabezudo. The Court found that the prosecution failed to establish an unbroken chain of custody, thereby creating reasonable doubt on the integrity of the corpus delicti. The legal logic hinges on the imperative of proving the identity of the dangerous drug with moral certainty. The Court noted several critical lapses. First, the prosecution did not offer any justifiable ground for the absence of the required witnesses during the physical inventory and photographing at the place of arrest, as mandated by law. The inventory was conducted later at the barangay hall, but the prosecution failed to explain why the witnesses were not present at the initial seizure. Second, there was a significant gap in the chain concerning the turnover from the forensic chemist to the court. While the chemist testified she placed the item in an envelope with her seal and kept it in a cabinet, there was no testimony on who had custody after her examination and how it was safeguarded until its presentation in court. The Court emphasized that every link in the chain—from seizure, marking, inventory, laboratory examination, to presentation in court—must be accounted for. These procedural breaches, unexplained by the State, compromised the identity of the drug evidence. Consequently, without the corpus delicti being proven beyond reasonable doubt, Cabezudo’s guilt cannot be sustained.