G.R. No. 239781 , February 05, 2020
People of the Philippines, Plaintiff-Appellee v. Eric Padua y Alvarez a.k.a. Jerick Padua y Alvarez, Accused-Appellant

FACTS

Accused-appellant Eric Padua y Alvarez was charged with violating Section 5, Article II of Republic Act No. 9165 (illegal sale of dangerous drugs). The prosecution’s version states that on February 5, 2009, a buy-bust operation was conducted in Muntinlupa City based on a tip. PO1 Bob Yangson acted as the poseur-buyer, and PO2 Rondivar Hernaez was the backup officer. Padua allegedly sold one heat-sealed plastic sachet containing 0.01 gram of Methylamphetamine Hydrochloride to PO1 Yangson in exchange for marked money. Upon the consummation of the sale, Padua was arrested. The seized item was marked “JP” at the police station, photographed, and later submitted to the crime laboratory, where it tested positive for the presence of dangerous drugs. The defense presented a different version, claiming Padua was arbitrarily arrested near his house, brought to the police station, forced to sign a document, and that the police attempted to extort money from his family. The Regional Trial Court found Padua guilty and sentenced him to life imprisonment and a fine. The Court of Appeals affirmed the RTC decision.

ISSUE

Whether the prosecution proved the guilt of the accused beyond reasonable doubt for the illegal sale of dangerous drugs, particularly in establishing the identity and integrity of the seized drug through strict compliance with the chain of custody requirements under Section 21 of Republic Act No. 9165 .

RULING

The Supreme Court ACQUITTED accused-appellant Eric Padua y Alvarez. The Court ruled that the prosecution failed to prove his guilt beyond reasonable doubt due to the buy-bust team’s non-compliance with the mandatory procedures under Section 21 of R.A. No. 9165 regarding the custody and handling of seized drugs. The prosecution did not present any justifiable ground for this non-compliance. Specifically, the required witnesses (an elected public official, a representative from the Department of Justice or the media, and the accused or his counsel) were not present during the physical inventory and photographing of the seized item immediately after seizure. The testimonies of the police officers did not mention the presence of these required witnesses. The Court emphasized that strict adherence to the chain of custody rule is crucial in drug cases to preserve the integrity and evidentiary value of the seized items. The prosecution’s failure to establish a valid cause for non-compliance and to prove an unbroken chain of custody created reasonable doubt as to the identity of the corpus delicti. Consequently, Padua’s guilt was not proven beyond reasonable doubt. The Court ordered his immediate release and directed the Philippine National Police to investigate the buy-bust team’s violation of Section 21.