GR 233747; (December, 2018) (Digest)
G.R. No. 233747 . December 05, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. NILA MALANA Y SAMBOLLEDO, ACCUSED-APPELLANT.
FACTS
The prosecution alleged that on October 19, 2011, in Camalaniugan, Cagayan, a buy-bust operation was conducted against accused-appellant Nila Malana based on a tip. A civilian informant acted as poseur-buyer and purchased a plastic sachet of shabu worth P500.00 from Malana at a waiting shed. Upon the pre-arranged signal, police officers arrested Malana. The police claimed to have recovered the marked money from her and conducted an inventory at the scene in the presence of barangay officials. The seized item tested positive for methamphetamine hydrochloride.
The defense presented a different narrative. Malana testified that she went to the location to meet the informant, Rex Cortez, to explain her inability to fully pay a debt. Cortez did not arrive. Instead, three men approached her, showed her a plastic sachet, and accused her of owning it. She was frisked, allegedly found with a P500 bill she denied having, and brought to the police station. She claimed she was forced to name drug personalities and was only shown the inventory documents after being returned to the scene.
ISSUE
Whether the prosecution proved the guilt of the accused beyond reasonable doubt for the illegal sale of dangerous drugs.
RULING
The Supreme Court ACQUITTED accused-appellant Nila Malana. The Court found that the prosecution failed to establish the integrity and identity of the seized drug, which is crucial in drug cases. The chain of custody was broken due to unjustified deviations from the procedure under Section 21 of Republic Act No. 9165 . The arresting officers did not immediately mark the seized item at the place of arrest. Testimony revealed the marking was done at the police station, not at the buy-bust site. Furthermore, while barangay officials witnessed the inventory, the required representatives from the media and the Department of Justice were absent. The prosecution offered no justifiable reason for this absence, failing to prove that earnest efforts were made to secure their presence. The procedural lapses cast reasonable doubt on whether the item presented in court was the same one allegedly seized from Malana. In light of these failures in the chain of custody, the presumption of innocence prevails. The Court emphasized that the State must prove guilt with moral certainty, and any doubt arising from procedural infirmities in handling the corpus delicti must be resolved in favor of the accused.