GR 233883; (January, 2019) (Digest)
G.R. No. 233883 . January 07, 2019
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. MARK VINCENT CORRAL Y BATALLA, ACCUSED-APPELLANT.
FACTS
This case stemmed from a buy-bust operation conducted by the Calamba City Police against accused-appellant Mark Vincent Corral y Batalla on August 24, 2013. The police alleged that they recovered a plastic sachet containing 0.03 gram of shabu from the sale. Upon arrest and frisking, another sachet with 0.18 gram of shabu, a crumpled aluminum foil strip, and a glass tooter were seized. The marking, inventory, and photography of the seized items were conducted at the barangay hall in the presence of Barangay Captain Antonino P. Trinidad. The items later tested positive for methamphetamine hydrochloride.
Accused-appellant denied the charges, claiming he was at home caring for his children when police officers barged in, assaulted him, searched his house, took his belongings, and brought him to the station to force him to reveal another person’s whereabouts. The Regional Trial Court convicted him for Illegal Sale of Dangerous Drugs but acquitted him of Illegal Possession of Dangerous Drugs and Drug Paraphernalia. The Court of Appeals affirmed the conviction, giving credence to the police officers’ testimonies and finding substantial compliance with the chain of custody.
ISSUE
Whether the Court of Appeals correctly upheld accused-appellant’s conviction for Illegal Sale of Dangerous Drugs.
RULING
No. The Supreme Court reversed the conviction and acquitted accused-appellant due to the prosecution’s failure to establish an unbroken chain of custody, which compromised the integrity of the corpus delicti. In drug cases, the identity of the dangerous drug must be established with moral certainty, requiring the prosecution to account for each link in the chain of custody from seizure to presentation in court. Section 21 of Republic Act No. 9165 mandates that the inventory and photography be conducted in the presence of the accused or his representative, and required witnesses, which at the time included a representative from the media and the Department of Justice, and any elected public official.
Here, the prosecution only presented a barangay official as a witness. It failed to offer any justifiable reason for the absence of the mandatory media and DOJ representatives. The police did not even attempt to contact these required witnesses. This constituted a clear breach of the prescribed procedure. The Court emphasized that while minor procedural lapses may be excused under justifiable grounds, the prosecution must positively explain such deviations. The utter disregard for the witness requirement, without any explanation, created reasonable doubt as to whether the shabu presented in court was the same item seized from accused-appellant. Consequently, the integrity and evidentiary value of the corpus delicti were not preserved, warranting acquittal.