G.R. No. 232645, February 18, 2019
People of the Philippines, Plaintiff-Appellee vs. Antonio Balderrama y De Leon, Accused-Appellant

FACTS

Accused-appellant Antonio Balderrama y De Leon was charged with violations of Sections 5 (Sale) and 11 (Possession) of Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) in two separate Informations. The charges stemmed from an incident on August 13, 2010, in Taguig City, where he was accused of selling and possessing 0.060 gram of methamphetamine hydrochloride (shabu). The prosecution’s version, based on testimonies of police officers, stated that a buy-bust team was formed after receiving information that accused-appellant was selling drugs. PO3 Antonio Reyes acted as the poseur-buyer, purchased one sachet of shabu for ₱500, and then arrested accused-appellant, from whom another sachet was recovered. The seized items were marked at the scene. An inventory was conducted at the police station in the presence of three barangay officials. The defense version, from accused-appellant’s testimony, claimed that men in civilian attire barged into his house without a warrant, searched it, and brought him to the police station where he was photographed with drugs and money. The Regional Trial Court convicted him for violation of Section 5 (sale) but acquitted him for violation of Section 11 (possession). The Court of Appeals affirmed the conviction. Accused-appellant appealed to the Supreme Court.

ISSUE

Whether the police officers complied with the chain of custody requirements under Section 21 of RA 9165 and its Implementing Rules and Regulations, particularly the requirement for the presence of mandatory witnesses during the inventory of seized drugs.

RULING

The Supreme Court REVERSED the assailed rulings and ACQUITTED accused-appellant. The Court found that the police officers failed to comply with the chain of custody rule under Section 21 of RA 9165. The required witnesses from the media and the Department of Justice (DOJ) were not present during the inventory; only barangay officials were present. The prosecution’s justification—that the operation happened too quickly—was not acceptable. The Court noted that the police had approximately eight hours (from 2:00 p.m. when the informant arrived to 10:00 p.m. when the operation commenced) to secure the presence of the required witnesses but failed to do so. The prosecution did not show any genuine and sufficient effort to contact these witnesses. This non-compliance, without justifiable grounds, compromised the integrity and evidentiary value of the seized items. Consequently, the accused-appellant’s guilt was not proven beyond reasonable doubt.