G.R. No. 232381, August 1, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. RYAN MARALIT y CASILANG, Accused-Appellant

FACTS

Accused-appellant Ryan Maralit was charged with illegal trade, transport, and delivery of dangerous drugs under Section 5 of Republic Act No. 9165. The prosecution alleged that on July 19, 2011, a PDEA team, acting on information from a confidential informant, conducted an entrapment operation in Sto. Tomas, La Union. An agent, posing as a buyer from Tarlac, arranged via text message to purchase two bricks of marijuana from an individual known as “RAM” for PHP 10,600.00. At the agreed location, Maralit, matching the description, approached the agent and handed over a brown paper bag containing the marijuana. He was immediately arrested.
The arresting team conducted an inventory and marking of the seized items at the place of arrest. They were able to secure the presence of two barangay officials and a media representative as witnesses. However, they failed to obtain a representative from the Department of Justice (DOJ), reasoning that the operation concluded after office hours and no DOJ representative was available. The seized items were later confirmed by forensic examination to be marijuana. The Regional Trial Court convicted Maralit, a decision affirmed by the Court of Appeals.

ISSUE

Whether the prosecution successfully established the identity and integrity of the seized dangerous drugs, considering the arresting team’s non-compliance with the witness requirement under Section 21 of R.A. No. 9165.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED accused-appellant Ryan Maralit. The Court emphasized that in prosecutions for illegal drugs, the State must prove beyond reasonable doubt the identity of the corpus delicti. This requires an unbroken chain of custody, with the procedure under Section 21 of R.A. No. 9165 designed to ensure the integrity of the seized items from seizure to presentation in court. The law mandates that the inventory and photography be conducted immediately after seizure and in the presence of the accused or his representative, a representative from the media AND the Department of Justice (DOJ), AND any elected public official.
Here, the arresting team unjustifiably failed to secure a DOJ representative. Their proffered justification—that the operation ended after office hours—was deemed insufficient. The Court ruled that the team made no earnest effort to comply, such as contacting available DOJ representatives on call. This constituted a glaring breach of the prescribed procedure. While the law allows deviations under justifiable grounds, the prosecution must convincingly explain the breach and prove that the integrity and evidentiary value of the items were preserved. The prosecution failed on both counts. The absence of a required insulating witness during the critical initial custody stage cast reasonable doubt on whether the marijuana presented in court was the very same substance seized from Maralit. Consequently, the identity and integrity of the corpus delicti were not established with moral certainty, warranting acquittal.