G.R. No. 246362, November 11, 2019
Melanie Grefaldo y De Leon, Petitioner, vs. People of the Philippines, Respondent.

FACTS

This case stemmed from an Information accusing petitioner Melanie Grefaldo of Illegal Possession of Dangerous Drugs under Section 11 of Republic Act No. 9165. The prosecution alleged that on March 22, 2012, police officers PO1 Denver Riñon and PO2 Rhene Bogay, while investigating illegal gambling, encountered petitioner acting suspiciously. Upon approach, two plastic sachets containing white crystalline substance fell from her pocket. The officers arrested her, seized and marked the sachets, brought her to the police station, photographed and inventoried the items, and forwarded them to the crime laboratory, where they tested positive for shabu. Petitioner denied the charge, claiming she was forcibly taken by unidentified men on March 21, 2012, and only learned of the drug charge during inquest on March 23, 2012. The Regional Trial Court found her guilty, which the Court of Appeals affirmed. Petitioner appealed to the Supreme Court, arguing the prosecution failed to comply with the witness requirement under Section 21 of RA 9165.

ISSUE

Whether the police officers’ non-compliance with the witness requirement under Section 21, Article II of RA 9165, specifically the absence of the required witnesses (a representative from the media, the Department of Justice, and any elected public official) during the inventory and photography of the seized drugs, without any justifiable reason, warrants the acquittal of the petitioner due to failure to establish the integrity of the corpus delicti.

RULING

The petition is meritorious. The Supreme Court reversed the decisions of the lower courts and acquitted petitioner Melanie Grefaldo. The Court held that the prosecution failed to establish an unbroken chain of custody due to unjustified non-compliance with the witness requirement mandated by Section 21 of RA 9165. The Inventory Report confirmed the absence of the required witnesses, a fact admitted by the apprehending officers. Their proffered justification—”lack of material time”—was deemed insufficient and unacceptable. The prosecution did not acknowledge or justify the absence of an elected public official and failed to demonstrate that the officers exerted genuine and sufficient efforts to secure the presence of the witnesses. Mere statements of unavailability, absent actual serious attempts to contact the required witnesses, do not constitute a justifiable ground for non-compliance. Consequently, the integrity and evidentiary value of the seized items were compromised, warranting petitioner’s acquittal on reasonable doubt.