G.R. No. 243936, September 16, 2019
People of the Philippines, Plaintiff-Appellee, vs. Vernie Antonio y Mabuti, Accused-Appellant.

FACTS

Accused-appellant Vernie Antonio y Mabuti 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). The charges stemmed from a buy-bust operation on August 20, 2016, in Makati City, where he allegedly sold one heat-sealed plastic sachet of methamphetamine hydrochloride (shabu) weighing 0.06 gram for PHP 500.00. A subsequent body search yielded two more sachets containing 0.09 gram of shabu. The Regional Trial Court (RTC) convicted Vernie, and the Court of Appeals (CA) affirmed the conviction. The prosecution’s evidence included the testimonies of the poseur-buyer (PO1 Byron Atilon) and the immediate back-up officer (PO2 Michelle Gimena), an Inventory Receipt, photographs, a Chain of Custody Form, and a Chemistry Report. The defense consisted solely of Vernie’s testimony, denying the accusations and claiming he was merely resting beside his tricycle when apprehended. On appeal to the Supreme Court, Vernie argued, among other points, that the corpus delicti and related documents were never properly identified in open court.

ISSUE

Whether the prosecution established the identity and integrity of the seized dangerous drugs beyond reasonable doubt, complying with the chain of custody requirements under Section 21, Article II of R.A. 9165, as amended.

RULING

The Supreme Court GRANTED the appeal, REVERSED and SET ASIDE the CA Decision, and ACQUITTED accused-appellant Vernie Antonio y Mabuti. The Court found that the prosecution failed to establish an unbroken chain of custody, thereby creating reasonable doubt as to the identity and integrity of the seized drugs. Specifically, the prosecution did not provide justifiable grounds for the absence of the required witnesses (a representative from the media and the Department of Justice) during the inventory, which was conducted only at the police station. Furthermore, the Chemistry Report was admitted based on a stipulation regarding the testimony of an investigator (PO3 Paredes) who had no personal knowledge of its preparation or the handling of the seized items by the forensic chemist, rendering it inadmissible hearsay evidence. The prosecution’s failure to account for these critical links in the chain of custody and to prove compliance with the mandatory procedural safeguards warranted acquittal.