G.R. No. 243811 . July 04, 2022.
CARLO VILLAMOR Y GEMINA, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

An Information was filed against petitioner Carlo Villamor for Illegal Possession of Dangerous Drugs under Section 11, Article II of R.A. 9165. The prosecution alleged that on June 12, 2012, police officers implemented a search warrant at Villamor’s residence in Batangas City. During the search, PO1 Falcutila found three plastic sachets containing white crystalline substance and one sachet with residue on top of a refrigerator in the living room. An inventory was conducted at the scene in the presence of Villamor, a media representative, a DOJ prosecutor, and a barangay official. The seized items were then turned over to the crime laboratory, where they tested positive for methamphetamine hydrochloride.
Villamor denied the accusation, claiming the evidence was planted. He testified that the police officers entered his house without a warrant, handcuffed him, and brought him to the barangay hall while they searched his home. He asserted he only saw the alleged drugs when he was shown them at the police station. The Regional Trial Court found him guilty, a decision affirmed by the Court of Appeals. Villamor elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals erred in affirming Villamor’s conviction for illegal possession of dangerous drugs despite alleged irregularities in the chain of custody of the seized items.

RULING

The Supreme Court granted the petition, reversed the lower courts’ decisions, and acquitted Carlo Villamor. The Court emphasized that in prosecutions for illegal possession of dangerous drugs, the identity and integrity of the corpus delicti must be established with moral certainty through an unbroken chain of custody. The Court found a critical gap in the chain immediately after the seizure. The testimony of PO1 Falcutila revealed that after marking the items at the scene, he placed them in a plastic container and kept them in his possession until they were turned over to the forensic chemist. However, he admitted that from the time of seizure until the turnover at the crime laboratory, the plastic container holding the evidence was not sealed. This failure to immediately secure the seized drugs in a sealed container created a significant doubt regarding the integrity of the evidence, as it presented an opportunity for tampering, alteration, or substitution. The prosecution’s evidence failed to account for who had custody of the unsealed evidence during transport or to rule out the possibility of contamination. Since the prosecution did not provide justifiable grounds for this deviation from the strict custodial procedures mandated by Section 21 of R.A. 9165, the integrity of the corpus delicti was compromised. Consequently, Villamor’s guilt was not proven beyond reasonable doubt, warranting his acquittal.