G.R. No. 233480, June 20, 2018
People of the Philippines, Plaintiff-Appellee, v. Melanie B. Mercader, Accused-Appellant.

FACTS

Accused-appellant Melanie B. Mercader was charged with Illegal Sale and Illegal Possession of Dangerous Drugs under Sections 5 and 11, Article II of R.A. No. 9165. The prosecution alleged that on September 8, 2003, a buy-bust team was formed based on a confidential informant’s tip. PO1 Christopher Anos acted as poseur-buyer and purchased a sachet of shabu from Mercader for PHP 200.00. Upon the pre-arranged signal, Mercader was arrested. A subsequent search yielded two more sachets from her person. The seized items were marked at the place of arrest, then brought to the police station for a request for laboratory examination, which later confirmed the presence of methamphetamine hydrochloride.
Mercader denied the charges, claiming she was accosted while with her children, that no drugs were found on her, and that she was brought to the police station where money was extorted from her. The Regional Trial Court convicted her of both charges. The Court of Appeals affirmed the conviction, giving credence to the police officers’ testimonies and finding the chain of custody of the seized drugs unbroken despite procedural lapses.

ISSUE

Whether the Court of Appeals erred in affirming Mercader’s conviction despite alleged breaches in the chain of custody of the seized dangerous drugs.

RULING

The Supreme Court acquitted Mercader. The Court emphasized that in drug-related prosecutions, the identity and integrity of the corpus delicti must be established with moral certainty through an unbroken chain of custody. The law requires the immediate physical inventory and photographing of seized items in the presence of the accused or her representative, an elected public official, and representatives from the DOJ and the media. The prosecution failed to justify non-compliance with these mandatory procedures.
The records showed that the inventory was conducted only at the police station in the presence of Mercader and a media representative, but without an elected public official or a DOJ representative. The prosecution offered no explanation for these absences. The apprehending officers also failed to strictly comply with the marking requirement, as the testimony revealed the marking was done at the police station, not immediately after seizure at the place of arrest as required. These unjustified deviations from the statutory procedure created reasonable doubt as to whether the items presented in court were the same ones seized from Mercader. Consequently, the integrity and evidentiary value of the corpus delicti were compromised, warranting acquittal.