G.R. No. 241778 , June 15, 2020
People of the Philippines, Plaintiff-Appellee, vs. Dennis Mejia y Cortez alias “Dormie,” Accused-Appellant.

FACTS

On August 28, 2015, police officers conducting an anti-criminality campaign in Tondo, Manila, witnessed a robbery/hold-up. They chased the suspects and apprehended accused-appellant Dennis Mejia y Cortez. Upon frisking him, SPO2 Ronald Mesina recovered a .38 caliber firearm and, from a belt bag, a Marlboro cigarette case containing three plastic sachets of a white crystalline substance suspected to be shabu. The sachets were marked at the place of arrest. The accused-appellant and the seized items were brought to a barangay office where a Certification, which also served as an inventory, was prepared and signed by Barangay Kagawad Arnulfo dela Cruz, a Barangay Tanod, and a Barangay Executive Officer. The items were then taken to the police station, after which SPO2 Mesina personally delivered them to the crime laboratory for examination. The forensic chemist confirmed the substance was methamphetamine hydrochloride. The accused-appellant was charged with Illegal Possession of Dangerous Drugs under Section 11, Article II of R.A. No. 9165 . He denied the charge, claiming the drugs were not recovered from him and he only saw them at the police station. The Regional Trial Court convicted him, a decision affirmed by the Court of Appeals. The accused-appellant appealed to the Supreme Court, arguing non-compliance with the chain of custody procedures under Section 21 of R.A. No. 9165 .

ISSUE

Whether or not accused-appellant’s conviction for illegal possession of dangerous drugs should be upheld, considering the alleged breaches in the chain of custody procedure under Section 21 of R.A. No. 9165 .

RULING

No. The Supreme Court reversed the conviction and acquitted the accused-appellant. The Court ruled that the prosecution failed to establish an unbroken chain of custody and to prove the integrity and identity of the seized drugs beyond reasonable doubt. The apprehending officers did not strictly comply with the witness requirements of Section 21. The inventory was conducted only in the presence of a barangay kagawad and other barangay officials, but there was no representative from the media or the Department of Justice (DOJ), as required by law at the time. The prosecution did not offer any justifiable ground for this non-compliance. Furthermore, the testimony of SPO2 Mesina created uncertainty about where the inventory was actually conducted—whether at the place of arrest or at the barangay office—which cast doubt on whether the items presented in court were the same ones seized from the accused-appellant. This failure to properly account for each link in the chain of custody, and the resulting doubt regarding the integrity of the corpus delicti, warranted acquittal.