GR 237769; (March, 2019) (Digest)
G.R. No. 237769 . March 11, 2019
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. EDWIN LABADAN Y MANMANO AND RAQUEL SAGUM Y MARTINEZ, ACCUSED-APPELLANTS.
FACTS
Accused-appellants Edwin Labadan and Raquel Sagum were charged with illegal sale of dangerous drugs under Section 5, Article II of R.A. No. 9165 . The prosecution alleged that on November 11, 2013, a buy-bust operation was conducted at their residence in Quezon City. PO3 Diomampo, acting as poseur-buyer, purchased a plastic sachet containing 5.39 grams of shabu from Labadan, with Sagum handing the item to him. After the transaction, the team arrested the accused. The seized item was marked at the scene by PO3 Diomampo.
The inventory and photography of the seized drugs were conducted at the Tatalon Barangay Hall. While the inventory receipt was signed by a Barangay Kagawad and the police team leader, the prosecution admitted that no representative from the Department of Justice (DOJ) or the media was present during the inventory. The police testified they tried but failed to secure such witnesses due to the commotion and unavailability. The item was later turned over to the investigator and then to the forensic chemist, whose testimony was stipulated.
ISSUE
Whether the prosecution established an unbroken chain of custody over the seized dangerous drug, thereby proving the guilt of the accused-appellants beyond reasonable doubt.
RULING
No. The Supreme Court reversed the conviction and acquitted the accused-appellants due to the prosecution’s failure to comply with the mandatory chain of custody requirements under Section 21 of R.A. No. 9165 , which created reasonable doubt as to the integrity of the seized evidence.
The law requires that the inventory and photographing of seized items be done immediately after seizure and in the presence of the accused or his representative, a representative from the media, the Department of Justice (DOJ), and any elected public official. The prosecution’s own evidence showed a glaring absence of the required insulating witnesses from the DOJ and the media during the inventory at the barangay hall. The police officers’ claim of attempting but failing to secure these witnesses was insufficient. The Court emphasized that the mere statement of unavailability, without a showing of earnest efforts to secure their presence—such as listing the names of the specific media and DOJ offices contacted, the persons spoken to, and the concrete actions taken—constitutes a deviation from the strict procedural safeguards. This failure to offer a justifiable reason for the non-compliance breached the chain of custody. While the marking was done at the scene, the subsequent broken links in the chain, particularly during the critical inventory stage, compromised the identity and integrity of the corpus delicti. Without the requisite proof that the substance seized was the same one presented in court, the accused-appellants’ guilt cannot be sustained beyond reasonable doubt. Consequently, they are entitled to acquittal.