GR 234686; (June, 2019) (Digest)
G.R. No. 234686 June 10, 2019
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. MICHAEL FRIAS Y SARABIA ALIAS “NICKER”, Accused-Appellant
FACTS
Accused-appellant Michael Frias was charged with Illegal Sale and Illegal Possession of Dangerous Drugs under Sections 5 and 11 of Republic Act No. 9165 . The prosecution alleged that during a buy-bust operation in Bacolod City, PDEA Agent Pinanonang, acting as poseur-buyer, purchased a sachet of shabu from Frias for PHP 500. Upon arrest, another sachet was recovered from Frias. The seized items were marked, inventoried, and photographed at the place of arrest in the presence of media representatives and barangay officials, and were later confirmed to be methamphetamine hydrochloride.
The defense presented a different version, claiming the PDEA agents forcibly entered their home without a warrant, found no illegal items on them, and coerced Frias to sign an inventory. The Regional Trial Court convicted Frias, a decision affirmed by the Court of Appeals. Frias appealed to the Supreme Court, arguing the prosecution failed to establish an unbroken chain of custody over the seized drugs.
ISSUE
Whether the prosecution successfully established the identity and integrity of the corpus delicti by proving an unbroken chain of custody in compliance with Section 21 of RA 9165.
RULING
The Supreme Court reversed the conviction and acquitted Michael Frias. The Court emphasized that in drug-related prosecutions, the State must prove with moral certainty the identity of the prohibited drug, which is the corpus delicti of the offense. This is established through a strict showing of an unbroken chain of custody under Section 21, Article II of RA 9165, as amended. The law requires the immediate physical inventory and photographing of seized items to be conducted in the presence of the accused or his representative, a representative from the media and the Department of Justice, and any elected public official.
The Court found a critical break in the chain of custody. The Certificate of Inventory and the testimony of the arresting officer confirmed that while media representatives and barangay officials were present during the inventory, there was no representative from the Department of Justice. The prosecution offered no explanation for this absence. The Court ruled that the presence of all three required witnesses is mandatory to insulate the proceedings from any suspicion of switching, planting, or contamination of evidence. The unjustified non-compliance constituted a fatal procedural gap that compromised the integrity and evidentiary value of the seized drugs. Consequently, the identity of the corpus delicti was not established beyond reasonable doubt, warranting acquittal.