G.R. No. 234155 . March 25, 2019.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. EDUARDO CARIÑO Y LEYVA, ACCUSED-APPELLANT.

FACTS

The accused-appellant, Eduardo Cariño, was charged with illegal sale of dangerous drugs, maintenance of a drug den, and illegal possession of dangerous drugs. The prosecution evidence, primarily from SPO2 Navarro, established that based on a tip from a prior arrestee, police conducted surveillance on July 30, 2009, at Cariño’s house. The officer witnessed Cariño purchase sachets from a neighbor and return to his house, where a “pot session” was later signaled. Cariño was arrested outside his house. Upon entry, police found on a table various drug paraphernalia and two plastic sachets containing white crystalline substance. Two additional sachets were found hidden in the cellphone of a visitor, Noel Manianglung. An inventory was conducted at the place of arrest in the presence of a barangay chairman and a DOJ representative, though Cariño refused to sign. The seized items were later examined and tested positive for shabu.
For the defense, Cariño testified he was at home treating a foot injury when police arrived without a warrant. He consented to a search, during which the two sachets were found in Manianglung’s possession. Manianglung then pointed to Cariño as the source. Cariño denied selling drugs but admitted to being a drug user. The RTC acquitted him of illegal sale but convicted him for maintaining a drug den and illegal possession of dangerous drugs. The CA affirmed the RTC’s decision.

ISSUE

Whether the prosecution proved the guilt of the accused-appellant for violation of Sections 6 and 11, Article II of R.A. No. 9165 beyond reasonable doubt, particularly in establishing the identity and integrity of the corpus delicti.

RULING

The Supreme Court REVERSED the CA decision and ACQUITTED the accused-appellant. The Court emphasized that in drug cases, the prosecution must establish with moral certainty the identity of the prohibited drug, constituting the corpus delicti. This requires an unbroken chain of custody over the seized items to preserve their integrity and evidentiary value. The Court found a critical broken link in this chain. The testimony of the forensic chemist, PSI Timario, revealed that after examination, she merely placed the specimens inside an envelope, marked it, and gave it to the evidence custodian. She did not, however, identify who specifically received the items from her or detail the manner of their storage and subsequent handling. This failure to account for the movement and safekeeping of the drugs after laboratory examination until their presentation in court created a gap in the chain of custody.
The Court ruled that this gap compromised the integrity of the evidence. The prosecution did not offer any justifiable reason for this lapse, nor did it present the evidence custodian to testify and complete the chain. Without proof that the evidence presented in court was the very same substance seized from the accused and examined, the element of corpus delicti was not established beyond reasonable doubt. Consequently, the presumption of innocence prevails. The acquittal extends to both charges, as the illegal possession charge directly relies on the compromised drug evidence, and the charge for maintenance of a drug den is fatally weakened by the same failure to preserve the integrity of the seized items central to the offense.