G.R. No. 243390 , October 05, 2020
People of the Philippines, Plaintiff-Appellee, vs. Alex Baluyot y Biranda, Accused-Appellant.

FACTS

Based on a tip, PDEA agents from Pampanga conducted a buy-bust operation in Caloocan City against accused-appellant Alex Baluyot. IO1 Molina acted as poseur-buyer and purchased one plastic sachet of shabu from Baluyot using marked money. Upon the signal, the team arrested Baluyot. The arresting officer, IO1 Pinto, recovered the marked bill from Baluyot and a medium plastic sachet containing two smaller sachets from his sling bag. The team left the site immediately due to perceived danger and proceeded to PDEA headquarters in Quezon City, where IO1 Molina marked the seized items and conducted an inventory. The items tested positive for methamphetamine hydrochloride.
Baluyot denied the charges, claiming he was merely arrested at his home without any drug transaction. He asserted that the prosecution failed to prove his guilt beyond reasonable doubt, particularly highlighting alleged breaches in the chain of custody of the seized drugs. The RTC convicted him for illegal sale and possession of dangerous drugs. The CA affirmed the conviction, prompting this appeal.

ISSUE

Whether the Court of Appeals erred in affirming Baluyot’s conviction despite alleged irregularities in the chain of custody of the seized drugs.

RULING

The Supreme Court reversed the conviction and acquitted Baluyot. The prosecution failed to establish an unbroken chain of custody, which is crucial in proving the identity and integrity of the corpus delicti in drug cases. The Court found unjustified deviations from the procedure under Section 21 of RA 9165. The marking of the seized items was not done immediately at the place of arrest but only later at the PDEA office, without a valid justification for this delay. The inventory and photography were also not conducted in the presence of the accused or any representative from the media, the Department of Justice, or an elected public official, as required by law.
The apprehending team offered no convincing reason for these lapses, merely citing “possible danger” as grounds for leaving the scene, which the Court found insufficient. The law requires the insulating presence of the required witnesses during the inventory to be “immediate or contemporaneous” with the seizure to prevent switching, planting, or contamination of evidence. Their absence, without a justifiable ground, compromised the integrity of the seized items. Consequently, the prosecution did not overcome the presumption of innocence, and the identity of the drugs as evidence was not preserved with moral certainty.