G.R. No. 234035 . August 19, 2019.
PEOPLE OF THE PHILIPPINES, APPELLEE, VS. CRISPIN MAMUYAC, JR. Y PALMA, APPELLANT.

FACTS

Appellant Crispin Mamuyac, Jr. y Palma was charged with illegal sale of dangerous drugs under Section 5, Article II of Republic Act No. 9165 . The prosecution alleged that on April 2, 2014, a buy-bust operation was conducted in Pasuquin, Ilocos Norte, where PO1 Alexson Rosal, acting as poseur-buyer, purchased one plastic sachet of shabu from the appellant for PHP 500.00. Upon consummation of the sale, the appellant attempted to flee and allegedly cocked a firearm before being subdued by the backup team. The seized item was marked at the police station, and an inventory was conducted.
The defense, however, presented a starkly different version. The appellant testified that on the said date and time, he was at home with his family when several armed men in civilian clothes forcibly entered without a warrant, handcuffed him, and brought him to the police station. He denied selling drugs and claimed the evidence was fabricated. The Regional Trial Court convicted the appellant, a decision affirmed by the Court of Appeals, prompting this final appeal.

ISSUE

The core issue is whether the guilt of the appellant for the illegal sale of dangerous drugs was proven beyond reasonable doubt.

RULING

The Supreme Court ACQUITTED the appellant. The Court emphasized that in prosecutions for illegal sale, the identity of the dangerous drug must be established with moral certainty, and the chain of custody rule must be strictly observed to preserve its integrity. The Court found the prosecution’s evidence on the chain of custody grievously lacking. Crucially, the required witnesses under Section 21 of RA 9165—an elected public official, a representative from the National Prosecution Service or the media—were not present during the physical inventory and photographing of the seized item at the police station. The prosecution offered no justifiable reason for this non-compliance.
The Court ruled that the procedural lapses, unexplained and unjustified, compromised the integrity and evidentiary value of the corpus delicti. Without the drug’s identity being preserved beyond reasonable doubt, the appellant’s guilt cannot be sustained. The presumption of innocence prevails. The Court further noted that the defense of frame-up, while commonly viewed with disfavor, gains credence in light of the police officers’ blatant disregard of the law’s mandatory safeguards. Consequently, the appellant’s conviction was reversed and set aside.