G.R. No. 235110 , January 08, 2020
Jesus Edangalino y Dionisio, Petitioner, vs. People of the Philippines, Respondent.

FACTS

On September 7, 2011, based on an informant’s tip, a buy-bust team was formed to target a certain “Amboy” in Barangay Malanday, Marikina City. PO1 Rey Lambino was designated as the poseur-buyer. In the early hours of September 8, 2011, the team proceeded to the location. PO1 Lambino and the informant approached “Amboy,” later identified as petitioner Jesus Edangalino. When “Amboy” presented a plastic sachet of suspected shabu worth P300.00, someone shouted a warning about police presence. Petitioner attempted to flee but was restrained by PO1 Lambino, who then introduced himself as a police officer and confiscated the plastic sachet. The seized item was immediately marked at the place of arrest with “RL/Amboy 09-08-2011,” photographed, and inventoried in the presence of the petitioner, who signed the certificate of inventory. The item was later examined and found positive for methamphetamine hydrochloride. Petitioner denied the charge, claiming he was merely accompanying a certain “Melvin” to a neighbor’s house to buy drugs and was subsequently framed when police arrived.

ISSUE

Whether the Court of Appeals gravely erred in affirming the petitioner’s conviction for violation of Section 11, Article II of Republic Act No. 9165 , despite the serious irregularities in the conduct of the police operation and the prosecution’s failure to establish the identity and integrity of the alleged confiscated drugs constituting the corpus delicti of the crime charged.

RULING

The Supreme Court granted the petition and reversed the decisions of the lower courts. The prosecution failed to establish an unbroken chain of custody of the seized dangerous drug, which is crucial to proving the corpus delicti. The apprehending officers did not comply with the mandatory witness requirement under Section 21 of RA 9165. The inventory and photographing of the seized item were not conducted in the presence of an elected public official, a representative from the National Prosecution Service, or the media. The prosecution did not offer any justifiable ground for this non-compliance. Furthermore, the police officers failed to immediately deliver the seized drug to the crime laboratory, as there was an unexplained delay of over twelve hours from the time of seizure (around 1:40 a.m.) to its delivery for examination (at 2:30 p.m. the same day). This delay, coupled with the absence of required witnesses, compromised the integrity and evidentiary value of the seized item. Consequently, petitioner’s guilt was not proven beyond reasonable doubt, and he was acquitted.