G.R. No. 239399 . March 25, 2019
ROLANDO P. DIZON, PETITIONER, V. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

An Information was filed against Rolando P. Dizon for violation of Section 11, Article II of R.A. No. 9165 (Comprehensive Dangerous Drugs Act of 2002) for possessing 3.0191 grams of methamphetamine hydrochloride. On November 26, 2003, NBI agents implemented a search warrant at Dizon’s residence. The team was accompanied by two barangay kagawads. During the search, agents recovered plastic sachets containing a crystalline substance from the pocket of a white ladies’ jacket on a bed. An inventory was prepared and markings were placed on the sachets in the presence of Dizon and the barangay officials. Forensic examination confirmed the presence of methamphetamine hydrochloride in several sachets.
Dizon denied the accusation, testifying that he was arrested near his home, brought inside, and not shown the search warrant. He claimed no knowledge of the jacket or the drugs, which he first saw at the Fiscal’s office. The Regional Trial Court convicted Dizon, a ruling affirmed by the Court of Appeals. The CA held that the integrity of the seized items was preserved despite procedural lapses, as the inventory was conducted with barangay officials present.

ISSUE

Whether the prosecution proved Dizon’s guilt beyond reasonable doubt, considering alleged non-compliance with the chain of custody requirements under Section 21 of R.A. No. 9165 .

RULING

The Supreme Court REVERSED the CA decision and ACQUITTED Dizon. The Court emphasized that compliance with the chain of custody procedure under Section 21 of R.A. No. 9165 is mandatory to ensure the integrity and evidentiary value of seized drugs. The law requires the immediate physical inventory and photographing of seized items 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 prosecution failed to establish compliance with these witness requirements. The inventory was conducted only in the presence of Dizon and two barangay kagawads. There was no representative from the media or the DOJ, and no justifiable ground was offered by the prosecution to explain this deviation. The Court ruled that lapses in procedure, when unacknowledged and unexplained, compromise the integrity of the corpus delicti. The CA erred in presuming that the presence of any two insulating witnesses sufficed; the law enumerates specific witnesses whose presence is required. Since the prosecution did not provide justifiable grounds for the procedural lapse and failed to prove the integrity of the seized items was preserved, Dizon’s guilt was not established beyond reasonable doubt. Acquittal is therefore warranted.