G.R. No. 233207 . August 20, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ANTHONY MADRIA Y HIGAYON, ACCUSED-APPELLANT.

FACTS

The case originated from a buy-bust operation on December 28, 2009, in Cagayan de Oro City. A civilian informant reported the illegal drug activities of Anthony Madria and Lorenzo De Ala. A PDEA team was formed, with IO1 Naomie Siglos acting as poseur-buyer. The team proceeded to the target area, where the informant approached Madria and De Ala. During the transaction, De Ala asked Siglos about the quantity, and upon her insistence to see the drugs first, Madria handed a sachet to De Ala, who then gave it to Siglos. After confirming it was shabu, Siglos handed the marked money to De Ala, who passed it to Madria. Siglos then gave the pre-arranged signal, leading to the arrest of both accused. A search of Madria yielded six more plastic sachets and the marked money. The team, citing growing darkness and an increasing crowd, immediately left the scene and conducted the inventory and photography of the seized items at the PDEA office. The items were later confirmed by a forensic chemist to be methamphetamine hydrochloride or shabu. The defense presented a different version, claiming Madria was arbitrarily apprehended while walking to a store, forced into a vehicle, and later coerced at the PDEA office to claim ownership of the drugs.

ISSUE

The core issue is whether the prosecution successfully proved the guilt of the accused beyond reasonable doubt for the illegal sale and possession of dangerous drugs, particularly in light of alleged non-compliance with the chain of custody requirements under Section 21 of Republic Act No. 9165 .

RULING

The Supreme Court acquitted Anthony Madria. The ruling hinged on the prosecution’s failure to establish an unbroken chain of custody, which compromised the integrity and evidentiary value of the seized drugs. The Court emphasized that in drug cases, the identity of the corpus delicti must be established with moral certainty. The buy-bust team’s deviation from the mandated procedure under Section 21 was unjustified. The officers conducted the physical inventory and photograph of the seized items at the PDEA office, not at the place of arrest or the nearest police station, citing “darkness” and a “growing crowd” as reasons. The Court found these grounds not to be justifiable. The apprehending team had control of the scene and the suspects; they could have cordoned the area or requested assistance to safely conduct the inventory immediately after seizure. Furthermore, the prosecution failed to show that earnest efforts were made to secure the presence of the required witnesses—a representative from the media, the Department of Justice, and an elected public official—during the inventory. This procedural lapse, without a credible explanation, created reasonable doubt as to whether the items presented in court were the same ones seized from the accused. Consequently, the presumption of regularity in the performance of official duties was overturned. The Court ruled that the integrity of the evidence was not preserved, leading to Madria’s acquittal and ordered his immediate release.