G.R. No. 238516 , February 27, 2019
People of the Philippines, Plaintiff-Appellee vs. Roger Rodriguez y Martinez, Accused-Appellant

FACTS

Accused-appellant Roger Rodriguez was charged with illegal sale and illegal possession of dangerous drugs. The prosecution alleged that a buy-bust operation was conducted wherein Rodriguez sold a sachet of shabu to a police poseur-buyer. Upon arrest, two additional sachets were seized from him. The police marked the seized items at the scene. However, the inventory and photography were conducted later at the police station, witnessed only by a local government employee, not the required witnesses under Section 21 of RA 9165. The defense claimed Rodriguez was arbitrarily arrested, not during a legitimate buy-bust.
The Regional Trial Court convicted Rodriguez. The Court of Appeals affirmed the conviction, ruling that the integrity and evidentiary value of the seized drugs were preserved despite deviations from the chain of custody protocol. Rodriguez appealed to the Supreme Court, arguing that the prosecution failed to establish an unbroken chain of custody and to justify the procedural lapses.

ISSUE

Whether the Court of Appeals erred in affirming the conviction despite the prosecution’s non-compliance with the chain of custody requirements under Section 21, Article II of RA 9165.

RULING

The Supreme Court reversed the conviction and acquitted Rodriguez. The Court emphasized that in drug cases, the State must prove an unbroken chain of custody to establish the identity and integrity of the corpus delicti beyond reasonable doubt. Strict compliance with Section 21’s procedure is required. The law mandates that the inventory and photography be conducted immediately after seizure and 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 comply. The inventory was done at the police station, not at the place of arrest, without any justifiable reason. Crucially, only a local government employee witnessed the inventory. The prosecution offered no explanation for the absence of the mandatory witnesses from the media and the DOJ, nor did it show any earnest effort to secure their presence. These unjustified deviations from the statutory procedure created reasonable doubt about the identity of the drugs allegedly seized from Rodriguez. Consequently, the integrity of the corpus delicti was compromised, warranting acquittal. The Court reiterated that the procedure under Section 21 is a matter of substantive law, and non-compliance, absent justifiable grounds, invalidates the seizure and custody of the evidence.