G.R. No. 238613. August 19, 2019.
THE PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. JEFFREY VICTORIA Y TARIMAN, ACCUSED-APPELLANT.

FACTS

The prosecution’s evidence established that a buy-bust operation was conducted against appellant Jeffrey Victoria on December 30, 2004, in Taytay, Rizal. Acting as poseur-buyer, PO1 Hector Lico approached appellant and handed a marked Php100 bill in exchange for a plastic sachet. Upon Lico’s pre-arranged signal, the arresting team apprehended Victoria. The seized item was marked and later examined by a forensic chemist, who confirmed it contained methamphetamine hydrochloride or shabu. The prosecution presented testimonies from the police officers involved to detail the operation and the chain of custody.
The defense presented a starkly different version. Appellant testified that he was arbitrarily arrested while playing billiards, assaulted by police officers, and subsequently framed for a drug offense he did not commit. He denied any involvement in the sale of dangerous drugs. The Regional Trial Court convicted him of violating Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002), a ruling affirmed by the Court of Appeals.

ISSUE

Whether the prosecution successfully proved the guilt of the accused beyond reasonable doubt for the illegal sale of dangerous drugs, particularly in establishing the integrity and identity of the corpus delicti.

RULING

The Supreme Court ACQUITTED appellant. The Court emphasized that in drug cases, the prosecution must prove not only the occurrence of the sale but also the identity of the prohibited drug with moral certainty. This requires an unbroken chain of custody over the seized item from the moment of seizure to its presentation in court. The Court found critical gaps in this chain. The testimony revealed that after the seizure, the item was merely marked with “RVM” at the police station, but the prosecution failed to establish who marked it, who had custody during transport to the crime lab, and who delivered it to the forensic chemist. The stipulated testimony of the chemist only confirmed receipt and examination, not the handling prior to that.
The Court ruled that these lapses compromised the integrity of the evidence. The prosecution’s failure to account for every link in the chain of custody created reasonable doubt as to whether the item presented in court was the same one seized from appellant. The presumption of regularity in the performance of official duty cannot prevail over the constitutional presumption of innocence and the prosecution’s failure to meet its burden of proof. Consequently, the guilt of the accused was not established beyond reasonable doubt, warranting acquittal.