G.R. No. 233744 February 28, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. WILSON RAMOS y CABANATAN, Accused-Appellant

FACTS

This case stemmed from a buy-bust operation conducted by PDEA operatives on November 12, 2010, in Quezon City. Intelligence Officer 1 Cesar Dealagdon, Jr., acting as poseur-buyer, met with accused-appellant Wilson Ramos after a confidential informant introduced them. Ramos demanded payment and, upon request, produced a black coin purse containing five plastic sachets of suspected shabu. After Dealagdon handed marked money and received the sachets, he gave a pre-arranged signal, leading to Ramos’s arrest. The seized items were later subjected to inventory at the police station in the presence of a Barangay Kagawad and were subsequently confirmed by laboratory examination to be methamphetamine hydrochloride.
Ramos pleaded not guilty, interposing the defenses of denial and frame-up. He claimed he was merely a tricycle driver who was mauled, forcibly taken, and falsely implicated. He asserted he only saw the alleged evidence for the first time after being taken from his barangay. The Regional Trial Court found him guilty of illegal sale of dangerous drugs under Section 5, Article II of Republic Act No. 9165 , a ruling affirmed by the Court of Appeals.

ISSUE

Whether the Court of Appeals correctly upheld Ramos’s conviction for illegal sale of dangerous drugs.

RULING

No. The Supreme Court reversed the conviction and acquitted Ramos due to the prosecution’s failure to establish an unbroken chain of custody, which compromised the integrity and evidentiary value of the seized drugs. For a successful prosecution, the identity of the dangerous drug must be established with moral certainty, requiring proof of an unbroken chain from seizure to presentation in court. The law mandates that the inventory and photography of seized items be conducted immediately after seizure and in the presence of the accused or his representative, a representative from the media and the Department of Justice, and any elected public official.
Here, the prosecution admitted that the inventory was not conducted at the place of arrest but at the police station, and it was witnessed only by a Barangay Kagawad. No representative from the media or the DOJ was present. The prosecution offered no justifiable ground for this deviation from the statutory procedure. The Court emphasized that while non-compliance may be excused under justifiable grounds, the prosecution bears the burden of proving such grounds and that the integrity of the evidence was preserved. The mere presence of a public official does not constitute substantial compliance when other required witnesses are absent without explanation. This procedural lapse created reasonable doubt as to whether the drugs presented in court were the same ones seized from Ramos, warranting acquittal.