GR 245334; (February, 2023) (Digest)
G.R. No. 245334. February 08, 2023
MARK RAMSEY JAVIER Y TITULAR, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.
FACTS
On June 1, 2016, during the election period, police officers in Muntinlupa City flagged down petitioner Mark Ramsey Javier y Titular for driving a motorcycle without a helmet. When he failed to produce a driver’s license and the motorcycle had no plate, he was arrested. During the arrest, a folding knife measuring about eight inches was found inside the motorcycle’s compartment and confiscated. A COMELEC Certification confirmed petitioner had no authority to carry a deadly weapon during the election period. Petitioner was charged with violating Section 261(p) of the Omnibus Election Code (BP 881), as amended by RA 7166. The Regional Trial Court (RTC) found him guilty, a decision affirmed by the Court of Appeals (CA). Petitioner appealed to the Supreme Court, arguing the knife was inadmissible as evidence and the prosecution failed to establish the elements of the crime.
ISSUE
Whether petitioner is guilty beyond reasonable doubt of violation of Section 261(p) of Batas Pambansa Bilang 881 (the Omnibus Election Code).
RULING
The Supreme Court GRANTED the petition and ACQUITTED petitioner. The prosecution failed to prove his guilt beyond reasonable doubt due to a broken chain of custody over the alleged deadly weapon (the folding knife).
The Court found that the police officers did not comply with the chain of custody rule as outlined in the PNP Criminal Investigation Manual. The marking of the evidence was inadequate (only marked with initials “MRTJ” without the date, time, and place of collection). More critically, the prosecution failed to account for the knife’s movement and safekeeping. The testimony only stated the knife was turned over to SPO4 Rolando Ty for safekeeping, but there was no evidence presented on how it was stored, who had access, or how it was preserved until its presentation in court. This failure to establish an unbroken chain of custody created reasonable doubt as to whether the knife presented in court was the same item allegedly seized from the petitioner. Consequently, the very existence of the corpus delicti was not proven with moral certainty. Since the first element of the crime—that the person was bearing, carrying, or transporting a deadly weapon—was not established beyond reasonable doubt, petitioner’s acquittal was warranted.