G.R. No. 242947 . July 17, 2019.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. MARIO MANABAT Y DUMAGAY, Accused-Appellant.

FACTS

Accused-appellant Mario Manabat y Dumagay was charged with violations of Sections 5 (Sale) and 11 (Possession), Article II of Republic Act No. 9165 (The Comprehensive Dangerous Drugs Act of 2002). The charges stemmed from a buy-bust operation on June 17, 2013, in front of ABC Printing Press, Miputak, Dipolog City. Based on information from a confidential informant, PO2 Lord Jericho N. Barral acted as poseur-buyer and handed a marked P500 bill to Manabat in exchange for one plastic sachet of suspected shabu. Upon consummation of the sale, Manabat was arrested. A subsequent body search yielded nine more plastic sachets of suspected shabu, the marked money, P150 in cash, and a cellphone. The seized items were marked, inventoried, and photographed in the presence of representatives from the DOJ, media, and the barangay. The sachets were submitted to the crime laboratory, where Forensic Chemical Officer PCI Anne Aimee T. Pilayre confirmed the contents to be methamphetamine hydrochloride. The Regional Trial Court found Manabat guilty, a decision affirmed by the Court of Appeals. Manabat appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for violations of Sections 5 and 11 of RA 9165, despite alleged non-compliance with the chain of custody rule under Section 21.

RULING

The Supreme Court granted the appeal, reversed the decisions of the lower courts, and acquitted accused-appellant Mario Manabat. The Court found that the prosecution failed to establish an unbroken chain of custody of the seized drugs, which is crucial in proving the identity and integrity of the corpus delicti. Specifically, there was a gap in the chain during the turnover from the arresting officers to the evidence custodian at the police station. The prosecution did not present the evidence custodian or any testimony to account for the safekeeping of the drugs from the time of the buy-bust until they were submitted to the crime laboratory. The testimony of the forensic chemist only covered the custody from the crime laboratory’s receipt of the items. This break in the chain, coupled with the failure to provide justifiable grounds for such non-compliance, created reasonable doubt as to whether the drugs presented in court were the same ones seized from the accused. Consequently, the prosecution failed to prove guilt beyond reasonable doubt.