G.R. No. 243615 , November 11, 2019
Edwin Gementiza Matabilas, Petitioner, v. People of the Philippines, Respondent.

FACTS

This case stemmed from an Information filed before the Regional Trial Court (RTC) accusing petitioner Edwin Gementiza Matabilas of Illegal Sale of Dangerous Drugs under Section 5, Article II of Republic Act No. 9165 . The prosecution alleged that on September 6, 2012, police officers conducted a buy-bust operation against petitioner in Kidapawan City, during which one plastic sachet containing 0.05 gram of white crystalline substance was recovered. After the arrest, police officers conducted the marking, inventory, and photography of the seized item in the presence of petitioner, a barangay kagawad (Ruel C. Anima), and a media representative (Romnick Cabaron). The seized item tested positive for methamphetamine hydrochloride or shabu. In his defense, petitioner denied the charge, claiming he was falsely apprehended and that the evidence was planted.
The RTC found petitioner guilty beyond reasonable doubt and sentenced him to life imprisonment and a fine. The Court of Appeals affirmed the conviction. Petitioner elevated the case to the Supreme Court via a petition for review on certiorari, which the Court treated as an ordinary appeal in the interest of substantial justice, given that the penalty imposed was life imprisonment.

ISSUE

Whether the police officers complied with the mandatory witness requirement under the chain of custody rule, specifically the presence of a representative from the Department of Justice (DOJ), during the inventory of the seized drugs.

RULING

No. The Supreme Court acquitted petitioner due to the prosecution’s failure to establish justifiable grounds for the apprehending officers’ non-compliance with the mandatory witness requirement under the chain of custody rule.
The law requires that the inventory and photography of seized items be conducted in the presence of the accused or his representative, and specific witnesses. For cases prior to the amendment of RA 9165 by RA 10640 (which took effect on August 7, 2014), the required witnesses are a representative from the media AND the Department of Justice (DOJ), and any elected public official. In this case, the inventory was witnessed only by a barangay kagawad (an elected public official) and a media representative. No DOJ representative was present.
The Court emphasized that strict compliance with the chain of custody procedure is required as a matter of substantive law. While non-compliance may be excused under the saving clause if there is a justifiable ground and the integrity of the evidence is preserved, the prosecution must prove such justifiable ground as a fact. Here, the prosecution failed to offer any explanation for the absence of a DOJ representative. The testimonies of the police officers merely confirmed the absence but did not show any genuine and sufficient effort to secure one. The Court noted that police officers have sufficient time to prepare for a buy-bust operation and make necessary arrangements to comply with the witness requirement. The unjustified deviation from the mandatory procedure compromised the integrity of the corpus delicti. Consequently, petitioner’s guilt was not proven beyond reasonable doubt, warranting his acquittal.