G.R. No. 243577. March 15, 2022
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. DANNY TAGLUCOP Y HERMOSADA, ACCUSED-APPELLANT.

FACTS

Accused-appellant Danny Taglucop y Hermosada was charged with violations of Sections 5 (Illegal Sale) and 11 (Illegal Possession), Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002), as amended. The charges stemmed from a buy-bust operation on July 2, 2016, in Carmen, Agusan del Norte. After surveillance confirmed reports of accused-appellant’s drug trade, a team was formed with SPO2 Jay C. Gilbuena as poseur-buyer. During the operation, accused-appellant sold one heat-sealed plastic sachet of suspected shabu to SPO2 Gilbuena for a marked P200.00 bill. Upon arrest, a body search yielded two more sachets from a matchbox in accused-appellant’s possession. The items were marked at the scene in the presence of barangay officials. The buy-bust team left the scene without a Department of Justice (DOJ) representative due to a gathering crowd and rain, proceeding to the police station where the DOJ and media representatives later signed the inventory. The seized items tested positive for methamphetamine hydrochloride. Accused-appellant denied the charges, claiming he was singing at a videoke when arrested and that evidence was planted.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant’s conviction, specifically concerning the prosecution’s compliance with the chain of custody requirements under Section 21 of Republic Act No. 9165, as amended.

RULING

The Supreme Court GRANTED the appeal, REVERSED the Court of Appeals Decision, and ACQUITTED accused-appellant. The Court found that the prosecution failed to establish an unbroken chain of custody, which compromised the integrity and identity of the seized drugs. The buy-bust team committed unjustified deviations from the prescribed procedure under Section 21. The required witnesses—an elected public official, a representative from the National Prosecution Service (DOJ), and a media representative—were not present at the time and place of seizure and inventory. The witnesses only signed the inventory at the police station, a significant lapse not justified by the alleged gathering crowd and rain, as the team could have conducted the inventory at a nearby secure location. Furthermore, the prosecution did not offer any explanation for the absence of the insulating witnesses during the seizure. The procedural breaches, coupled with the failure to provide justifiable grounds, created reasonable doubt on the corpus delicti. Consequently, accused-appellant’s guilt was not proven beyond reasonable doubt.