GR 234040; (June, 2019) (Digest)
G.R. No. 234040 June 26, 2019
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. AUGUSTO N. MAGANON, Accused-Appellant
FACTS
Accused-appellant Augusto Maganon was charged with illegal sale and illegal possession of dangerous drugs. The prosecution alleged that a buy-bust operation was conducted on November 23, 2014, where PO1 Marvin Santos, acting as poseur-buyer, purchased two sachets of shabu from Maganon. Upon arrest, four more sachets were recovered from him. The seized items were marked and inventoried at the barangay hall in the presence of Maganon, Barangay Captain Engracio Santiago, and a representative from the Anti-Drug Abuse Council. The Regional Trial Court convicted Maganon, a ruling affirmed by the Court of Appeals.
The defense presented a different version, claiming Maganon was arbitrarily arrested at his home on November 22, 2014, and that the evidence was planted. He denied any involvement in the sale or possession of illegal drugs.
ISSUE
Whether the prosecution established the identity and integrity of the seized dangerous drugs with moral certainty, complying with the chain of custody requirements under Section 21 of Republic Act No. 9165, as amended.
RULING
The Supreme Court REVERSED the conviction and ACQUITTED accused-appellant Augusto Maganon. The Court emphasized that in drug-related prosecutions, the State must prove an unbroken chain of custody to establish the identity of the corpus delicti beyond reasonable doubt. The law mandates that the inventory and photographing of seized items be conducted immediately after seizure and confiscation, 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 failed to justify the deviation from this procedure. The inventory was not conducted at the place of arrest but at the barangay hall, without any explanation for this transfer. Crucially, the required witnesses were not all present. While a barangay official was present, there was no representative from the media or the Department of Justice. The prosecution offered no justifiable ground for this absence, merely stating that none arrived. This constitutes a substantial gap in the chain of custody. The integrity and evidentiary value of the seized items were therefore compromised, creating reasonable doubt as to whether the items presented in court were the same ones allegedly seized from the accused. Consequently, his guilt was not proven beyond reasonable doubt.