GR 241251; (December, 2019) (Digest)
G.R. No. 241251 , December 10, 2019
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. SAMMY GLOBA Y COTURA, A.K.A. “JR” AND LOUIE ANADIA Y LUGARPO, ACCUSED-APPELLANTS.
FACTS
Accused-appellants Sammy Globa and Louie Anadia were charged with illegal sale of dangerous drugs under Section 5, Article II of R.A. No. 9165 . The prosecution evidence established that a buy-bust operation was conducted on July 31, 2012, in Quezon City. PO2 Jomar Manaol acted as poseur-buyer and purchased three heat-sealed sachets of shabu with a total weight of 97.91 grams from the accused-appellants. After the transaction, the buy-bust team arrested the accused-appellants and recovered the buy-bust money. An inventory, marking, and photographing of the seized items were conducted at the place of arrest in the presence of the accused-appellants, Barangay Captain Eduardo Firmalino, and a media representative, Dennis Datu of DZMM. The seized items were later examined and tested positive for methamphetamine hydrochloride. The defense presented a different version, claiming they were arrested during a drinking session and that the drugs were planted.
ISSUE
Whether the prosecution established an unbroken chain of custody of the seized dangerous drugs, thereby proving the guilt of the accused-appellants beyond reasonable doubt.
RULING
The Supreme Court REVERSED and SET ASIDE the Decision of the Court of Appeals and ACQUITTED the accused-appellants on the ground of reasonable doubt. The Court found that the police officers unjustifiably failed to comply with the mandatory requirements of Section 21, Article II of R.A. No. 9165 and its Implementing Rules and Regulations. Specifically, the apprehending team did not conduct the physical inventory and photographing of the seized items immediately after seizure and confiscation as required by law. The inventory was conducted only after the arrival of the barangay captain and media representative, which constituted an unjustified delay. The prosecution failed to recognize this lapse, present a justification for it, or explain that reasonable efforts were made to comply with the procedure. This breach compromised the integrity and evidentiary value of the seized items, which is crucial in establishing the corpus delicti of the crime. The presumption of innocence prevails, and the prosecution’s failure to prove an unbroken chain of custody warrants acquittal.