G.R. No. 243635 , November 27, 2019
People of the Philippines, Plaintiff-Appellee, vs. Priscila Ruiz y Tica, Accused-Appellant.

FACTS

On February 26, 2015, police officers conducted a buy-bust operation against accused-appellant Priscila Ruiz based on a tip. PO2 Aldwin Paulo Tibuc acted as the poseur-buyer. At Ruiz’s sari-sari store, the confidential informant asked to purchase drugs. Ruiz handed one plastic sachet of shabu to PO2 Tibuc in exchange for a marked P500 bill. Upon the pre-arranged signal, back-up officers arrested Ruiz. PO2 Tibuc seized Ruiz’s crossbody bag, which contained 14 more plastic sachets of shabu and drug paraphernalia. The items were marked at the scene. The accused and the seized items were brought to the police station in Calamba, Laguna for inventory and photography, which was witnessed by a media representative. The sachets tested positive for methamphetamine hydrochloride. Ruiz was charged with Illegal Sale, Illegal Possession of Dangerous Drugs, and Illegal Possession of Drug Paraphernalia under R.A. 9165. The Regional Trial Court convicted Ruiz for Illegal Sale and Illegal Possession but acquitted her for Illegal Possession of Drug Paraphernalia. The Court of Appeals affirmed the conviction, ruling that the chain of custody was established and that conducting the inventory at the police station was justified for a warrantless arrest.

ISSUE

Whether the Court of Appeals erred in affirming the conviction, specifically regarding the compliance with the chain of custody requirements under Section 21 of R.A. 9165.

RULING

The Supreme Court REVERSED and SET ASIDE the Decision of the Court of Appeals and ACQUITTED accused-appellant Priscila Ruiz. The Court found a broken chain of custody due to the prosecution’s failure to establish the identity and integrity of the seized drugs with moral certainty. The buy-bust team did not comply with the witness requirement under Section 21 of R.A. 9165. The inventory was conducted only in the presence of a media representative, with no elected public official or representative from the National Prosecution Service or the Department of Justice. The prosecution offered no justifiable reason for this absence. Furthermore, the prosecution failed to present the testimony of the forensic chemist to affirm the integrity of the specimens received and examined, creating another gap in the chain. The unjustified non-compliance with the witness requirement and the absence of the forensic chemist’s testimony compromised the integrity and evidentiary value of the corpus delicti, warranting acquittal.