G.R. No. 243390 , October 05, 2020
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ALEX BALUYOT Y BIRANDA, ACCUSED-APPELLANT.

FACTS

Accused-appellant Alex Baluyot was charged with Illegal Sale and Illegal Possession of Dangerous Drugs under Republic Act No. 9165 . The prosecution alleged that based on information from a confidential informant, a PDEA team from Pampanga conducted a buy-bust operation in Caloocan City. IO1 Molina acted as poseur-buyer and purchased one sachet of shabu from Baluyot. Upon the pre-arranged signal, the team arrested Baluyot. The arresting officer recovered the marked money from him and, from his sling bag, a medium plastic sachet containing two smaller sachets of shabu. The items were marked and inventoried at the PDEA headquarters in Quezon City, not at the place of arrest, due to alleged security concerns.
Baluyot interposed the defense of denial and frame-up. He testified that PDEA agents suddenly arrived at his house, arrested him at gunpoint, and brought him to their office where he was shown the alleged drugs. He claimed the buy-bust story was fabricated.

ISSUE

Whether the prosecution proved the guilt of the accused beyond reasonable doubt for violations of Sections 5 and 11, Article II of R.A. No. 9165 , given the alleged non-compliance with the chain of custody rule.

RULING

The Supreme Court ACQUITTED accused-appellant Alex Baluyot. The prosecution failed to establish an unbroken chain of custody, which is crucial in drug cases to prove the identity and integrity of the corpus delicti. The Court found unjustified deviations from the procedure under Section 21 of R.A. No. 9165 . The marking of the seized items, a critical first step in the chain, was not done immediately at the place of arrest or at the nearest police station. The officers’ mere claim of “possible danger” was insufficient to justify conducting the inventory and marking at their distant headquarters in Quezon City, as they failed to show earnest efforts to secure the area or to have the required witnesses present. This lapse created doubt about whether the items presented in court were the same ones seized from the accused.
Furthermore, the arresting officer admitted he did not see the contents of the sling bag at the scene; it was only opened later by the poseur-buyer at the headquarters. This break in the chain of custody, coupled with the unjustified procedural lapses, compromised the integrity of the evidence. In cases involving minute quantities of drugs, as in the sale charge, the State bears a heavier burden to show meticulous compliance with the chain of custody rule. The presumption of regularity in the performance of official duty cannot prevail over the constitutional presumption of innocence and the prosecution’s failure to account for the seized drugs properly. Consequently, the guilt of the accused was not proven beyond reasonable doubt.