G.R. No. 234033 . July 30, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. AMADO BALUBAL Y PAGULAYAN, ACCUSED-APPELLANT.

FACTS

The prosecution’s evidence established that on June 4, 2013, a PDEA team conducted a buy-bust operation in Solana, Cagayan, against appellant Amado Balubal based on a tip from a confidential informant. IO1 Mary Jane Gaayon acted as the poseur-buyer and was provided with marked money. The informant introduced Gaayon to appellant, who, upon receiving payment, handed over a heat-sealed plastic sachet. Gaayon gave the pre-arranged signal, and appellant was apprehended after a brief chase. The seized item was marked, and an inventory was conducted at the police station in the presence of appellant, barangay kagawads, and an alleged Department of Justice representative. The sachet tested positive for methamphetamine hydrochloride.
Appellant presented a different version, claiming he was illegally arrested. He testified that while waiting for a jeepney, men in civilian clothes forcibly pulled him from the vehicle, handcuffed him, and brought him to the police station. He denied any involvement in a drug sale. The defense witness, Agnes Gabona, corroborated seeing a white vehicle and men in civilian clothes in the area but did not witness the actual arrest.

ISSUE

Whether the prosecution successfully proved appellant’s guilt for illegal sale of dangerous drugs beyond reasonable doubt, particularly in establishing the integrity and evidentiary value of the seized item through strict compliance with the chain of custody rule under Section 21 of Republic Act No. 9165 .

RULING

The Supreme Court acquitted appellant. The ruling hinged on the prosecution’s failure to establish an unbroken chain of custody, which is crucial in proving the identity and integrity of the seized drugs—the corpus delicti of the offense. The Court emphasized that non-compliance with the procedural safeguards under Section 21 of RA 9165, as amended, raises reasonable doubt. Specifically, the prosecution did not offer any justifiable ground for its deviation from the mandatory witness requirement during the physical inventory and photographing of the seized item.
The inventory was purportedly witnessed by a DOJ representative, but the prosecution did not present this person to testify, nor did it explain his absence. This failure to establish his identity and the lack of explanation for not securing the presence of the required witnesses—an elected public official, a representative from the media, and from the DOJ—constituted a fatal gap in the chain of custody. The Court reiterated that while strict compliance may not always be possible, the prosecution must credibly explain any deviation. Here, the unjustified non-compliance, coupled with the procedural lapses, compromised the integrity of the evidence. Consequently, the identity of the corpus delicti was not preserved with moral certainty, warranting acquittal based on reasonable doubt.