G.R. No. 232940 , January 14, 2019
Dennis Loayon y Luis, Petitioner, vs. People of the Philippines, Respondent.

FACTS

This case stemmed from an Information charging petitioner Dennis Loayon with Illegal Possession of Dangerous Drugs. The prosecution alleged that on February 24, 2010, a buy-bust team in Quezon City targeted a certain “Awang.” Before a transaction could occur, Awang’s companion, later identified as Loayon, shouted a warning, prompting both to flee. Police officers chased and arrested Loayon, recovering a plastic sachet he allegedly threw during the pursuit. The seized item was later marked, inventoried, and photographed at the police station in the presence of a Barangay Kagawad. Forensic examination confirmed the sachet contained 0.03 gram of shabu.
Loayon denied the accusation, claiming he was merely apprehended while looking for his wife and was misidentified as Awang. The Regional Trial Court convicted Loayon, a ruling affirmed by the Court of Appeals. Both courts found the elements of the crime present and ruled there was substantial compliance with the chain of custody rule, giving credence to the police officers’ testimonies over Loayon’s denial.

ISSUE

Whether the Court of Appeals erred in affirming Loayon’s conviction despite an alleged breach in the chain of custody of the seized dangerous drugs.

RULING

The Supreme Court granted the petition and acquitted Loayon. The Court emphasized that in drug cases, the identity and integrity of the corpus delicti must be established with moral certainty through an unbroken chain of custody. A critical link in this chain is the witnessing requirement under Section 21, Article II of Republic Act No. 9165 . The law mandates that the inventory and photography be conducted in the presence of the accused or his representative, and crucially, a representative from the media AND the Department of Justice, AND any elected public official.
Here, the prosecution only presented a Barangay Kagawad as a witness. The apprehending officers offered no justifiable explanation for their failure to secure the presence of the required insulating witnesses—a media representative and a DOJ representative. This constituted a substantial gap in the chain of custody. The Court ruled that the prosecution failed to provide a credible explanation for this procedural lapse, which compromised the integrity of the evidence. Without proof that the integrity and evidentiary value of the seized item were preserved, Loayon’s guilt could not be established beyond reasonable doubt. Consequently, his acquittal was warranted.