G.R. No. 248333 , September 08, 2020
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, vs. KHALED FIRDAUS ABBAS Y TIANGCO, ACCUSED-APPELLANT.

FACTS

The prosecution alleged that a buy-bust operation was conducted against appellant Khaled Firdaus Abbas for selling 24.46 grams of shabu to a police poseur-buyer. The transaction occurred inside a vehicle on December 29, 2013, in Quezon City. After the sale, the apprehending team arrested the appellant, seized the marked money, and confiscated the drug evidence. The seized item was marked at the scene, and an inventory was conducted, which was signed by a media representative and a barangay official who was not an elected officer. The item was later subjected to laboratory examination, which confirmed the presence of methamphetamine hydrochloride.
The appellant denied the accusation, claiming he was arbitrarily arrested by police officers who blocked his path, took his personal belongings, and later forced him to sign a blank document. He alleged the arrest was a frame-up and that the officers attempted to extort money from his family. The Regional Trial Court convicted him of illegal sale of dangerous drugs under Section 5 of Republic Act No. 9165 , a decision affirmed by the Court of Appeals.

ISSUE

Whether the prosecution established the appellant’s guilt beyond reasonable doubt for the illegal sale of dangerous drugs, particularly in preserving the integrity and evidentiary value of the seized item through compliance with the chain of custody rule under Section 21 of R.A. No. 9165 .

RULING

The Supreme Court REVERSED the conviction and ACQUITTED the appellant. The prosecution failed to prove an unbroken chain of custody, which is crucial in establishing the identity and integrity of the seized drugs. The Court emphasized that in drug cases, the State must account for each link in the chain: from seizure, marking, inventory, laboratory examination, to presentation in court. Here, the inventory was not conducted in the presence of the required witnesses as mandated by law. The presence of an elected public official during the inventory is indispensable, and the prosecution offered no justifiable reason for the absence of such an official. The barangay representative who signed was not an elected official, and the media representative had no personal knowledge of the seizure’s source. This procedural lapse created reasonable doubt on whether the item presented in court was the same one seized from the appellant. The Court ruled that the integrity and evidentiary value of the corpus delicti were compromised, warranting acquittal.