G.R. No. 241631 . March 11, 2019
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. RODEL TOMAS Y ORPILLA, ACCUSED-APPELLANT.

FACTS

Accused-appellant Rodel Tomas y Orpilla was charged with illegal sale of dangerous drugs under Section 5 of Republic Act No. 9165 . The prosecution alleged that on May 8, 2011, a buy-bust operation was conducted in Tuguegarao City where Tomas sold two plastic sachets containing 7.69 grams of shabu to a PDEA poseur-buyer in exchange for marked money. Upon arrest, the items were seized, marked, inventoried, and photographed at the PDEA office in the presence of Tomas, a barangay chairman, and a media representative. The seized items tested positive for methamphetamine hydrochloride.
The defense presented a different version, claiming Tomas was arbitrarily arrested while buying medicine, mauled, and forced to admit ownership of drugs he did not possess. He denied any involvement in a drug transaction. The Regional Trial Court convicted Tomas, a decision affirmed by the Court of Appeals, prompting this final appeal before the Supreme Court.

ISSUE

Whether the prosecution successfully established the identity and integrity of the seized dangerous drugs, which is crucial to prove the corpus delicti of the crime beyond reasonable doubt.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED accused-appellant Rodel Tomas. The Court emphasized that in drug-related prosecutions, the State must prove with moral certainty the identity of the prohibited drug, ensuring it is the very same item seized from the accused and presented in court. This is established through an unbroken chain of custody, with strict compliance with the procedure under Section 21 of RA 9165, particularly the 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 Court found a critical gap in the chain of custody. The prosecution failed to account for the movement and handling of the seized drugs from the time they were turned over by the forensic chemist, PSI Tuazon, after examination, until their presentation in court. No testimony was offered to detail who had custody of the evidence after the laboratory examination, how it was preserved, and the precautions taken to prevent tampering or substitution. This broken link created reasonable doubt on whether the drugs presented in court were the same ones allegedly bought from Tomas. The prosecution’s non-compliance with the chain of custody rule was not justified, as it did not prove any genuine effort to secure the required witnesses for the inventory or provide a credible explanation for the lapse. Consequently, the identity and integrity of the corpus delicti were compromised, warranting acquittal.