GR 248010; (September, 2020) (Digest)
G.R. No. 248010 , September 08, 2020
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. HENRY SORIANO Y SORIANO, ACCUSED-APPELLANT.
FACTS
Accused-appellant Henry Soriano was charged with the illegal sale of dangerous drugs under Section 5, Article II of R.A. No. 9165 . The prosecution alleged that on December 10, 2010, a buy-bust operation was conducted in La Trinidad, Benguet, where a poseur-buyer purchased 0.04 grams of shabu from Soriano. The police officers marked the seized item at the place of arrest and later conducted an inventory at the police station in the presence of a barangay official, a DOJ representative, and a media representative. The item tested positive for methamphetamine hydrochloride.
At trial, Soriano claimed he was merely waiting for a ride when he was illegally arrested and framed. He argued the prosecution failed to establish the integrity and identity of the seized drug due to the police’s non-compliance with the chain of custody requirements under Section 21 of R.A. No. 9165 . The Regional Trial Court convicted him, a decision affirmed by the Court of Appeals.
ISSUE
Whether the prosecution successfully established an unbroken chain of custody over the seized dangerous drug, thereby proving the guilt of the accused beyond reasonable doubt.
RULING
No. The Supreme Court reversed the conviction and acquitted Henry Soriano. The Court emphasized that in prosecutions for illegal drug sale, the identity of the illicit drug must be established with moral certainty, and every link in the chain of custody must be accounted for. The Court found a critical break in the chain immediately after seizure. While the marking was done at the place of arrest, the required physical inventory and photographing under Section 21 were not conducted at the same place or at the nearest police station. Instead, these were done later at Camp Bado Dangwa. The law mandates these steps be undertaken immediately after seizure and confiscation to prevent switching, planting, or contamination of evidence. The prosecution offered no justifiable reason for this deviation. Given the miniscule amount of 0.04 grams involved, which is susceptible to tampering, strict compliance with the procedure is essential. The failure to adhere to the mandated chain of custody protocol compromised the integrity of the evidence, creating reasonable doubt as to whether the item presented in court was the same one seized from the accused. Consequently, Soriano’s guilt was not proven beyond reasonable doubt.