G.R. No. 233653 September 05, 2018
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. RICARDO GUANZON Y CENETA, ACCUSED-APPELLANT.

FACTS

Accused-appellant Ricardo Guanzon was charged with illegal sale and possession of dangerous drugs. The prosecution alleged that on July 28, 2003, a buy-bust operation was conducted where PO2 Hernandez, acting as poseur-buyer, purchased a sachet of shabu from Guanzon. Upon arrest, another sachet was recovered from him. The seized items were marked at the police station and later submitted to the crime laboratory, where they tested positive for methamphetamine hydrochloride. Guanzon denied the charges, claiming he was arbitrarily arrested at a friend’s house and that the evidence was fabricated.
The Regional Trial Court convicted Guanzon, a decision affirmed by the Court of Appeals. The courts found the testimonies of the police officers credible and ruled that the chain of custody over the seized drugs was sufficiently established. Guanzon appealed to the Supreme Court, arguing that the prosecution failed to prove an unbroken chain of custody as required by Section 21 of Republic Act No. 9165 .

ISSUE

Whether the prosecution successfully established the identity and integrity of the corpus delicti by proving an unbroken chain of custody over the seized dangerous drugs, thereby proving Guanzon’s guilt beyond reasonable doubt.

RULING

The Supreme Court REVERSED the appellate court’s decision and ACQUITTED Ricardo Guanzon. The Court emphasized that in drug-related prosecutions, the identity of the dangerous drug must be established with moral certainty, and this requires an unbroken chain of custody. The prosecution must account for each link in the chain: from seizure, marking, turnover, laboratory examination, to presentation in court. Any gap or unexplained deviation from the procedural safeguards raises doubt on the integrity of the evidence.
The Court found critical gaps in the chain of custody. First, the prosecution failed to establish who had custody of the drugs from the time of seizure at the scene until their marking at the police station. The testimonies did not specify who physically possessed and transported the items. Second, there was no testimony from the forensic chemist on the handling and analysis of the specimens received in the laboratory, creating another break. The prosecution also did not offer any justifiable reason for these procedural lapses. The marked money was also not presented as evidence. Consequently, the integrity and identity of the corpus delicti were compromised. Failure to prove an unbroken chain of custody warrants acquittal, as the presumption of innocence must prevail. Guanzon was ordered immediately released.