GR 242520; (November, 2021) (Digest)
G.R. No. 242520. November 15, 2021.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. KEVIN CASTILLO Y GALANG, ACCUSED-APPELLANT.
FACTS
Accused-appellant Kevin Castillo y Galang was charged with Illegal Sale of Dangerous Drugs under Section 5, Article II of Republic Act No. 9165. The prosecution alleged that on December 11, 2015, in Quezon City, Castillo sold 0.50 gram of methamphetamine hydrochloride (shabu) to a police poseur-buyer for PHP 2,500.00 during a buy-bust operation. The prosecution’s evidence, primarily from PO3 Geronimo Lazo, established that after the transaction, Castillo was arrested, and the seized drugs were marked, inventoried, and photographed at the police station in the presence of Castillo, a barangay kagawad, and a media representative. The forensic examination confirmed the substance was shabu. Castillo denied the accusation, claiming he was arbitrarily arrested while buying food and that the police officers tried to force him to admit knowing someone named Buboy Gomez. The Regional Trial Court convicted Castillo, a decision affirmed by the Court of Appeals. Castillo appealed to the Supreme Court.
ISSUE
Whether the prosecution established Castillo’s guilt for Illegal Sale of Dangerous Drugs beyond reasonable doubt, particularly in complying with the chain of custody rule under Section 21, Article II of RA 9165.
RULING
The Supreme Court ACQUITTED accused-appellant Kevin Castillo y Galang. The Court found that while the prosecution established the elements of illegal sale, it failed to prove compliance with the chain of custody rule, which is crucial to establishing the integrity and evidentiary value of the seized drugs as the corpus delicti. The Court noted that the marking, inventory, and photographing of the seized items were conducted at the police station, not at the place of arrest or the nearest police station, without any justifiable reason for the deviation. The apprehending team offered no explanation for not conducting the inventory immediately after seizure, as required by law. This gap in the chain of custody created reasonable doubt as to whether the drugs presented in court were the same ones seized from Castillo. Consequently, the prosecution failed to prove his guilt beyond reasonable doubt. Castillo was ordered immediately released from detention unless held for another lawful cause.