G.R. No. 250307 , February 21, 2023
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, VS. ROBERT UY y TING, ONG CHI SENG @ JACKIE ONG or ARCHIE, CO CHING KI @ CHAI ONG, TAN TY SIAO, GO SIAK PING, JAMES GO ONG @ WILLIAM GAN, Accused, ROBERT UY y TING, Accused-Appellant.

FACTS

This case involves two incidents. First, on November 10, 2003, accused-appellant Robert Uy was apprehended while driving a Mitsubishi Lancer. Police officers found a box in the car containing five plastic bags of white crystalline substance, later confirmed as 9,384.7 grams of shabu. He and his co-accused were charged with illegal delivery/transportation of dangerous drugs under Section 5 of Republic Act No. 9165 . Second, on November 11, 2003, a search warrant was implemented at a warehouse in Mapulang Lupa, Valenzuela City, leased by accused Willie Gan, leading to the confiscation of approximately 119.08 kilograms of shabu and 111.20 kilograms of chloromethamphetamine hydrochloride. All accused were charged with illegal possession under Section 11 of the same law. The Regional Trial Court convicted Uy on both charges. The Court of Appeals affirmed the conviction. Uy appealed to the Supreme Court.

ISSUE

Whether the police officers’ unjustified deviations from the chain of custody rule under Republic Act No. 9165 cast reasonable doubt on the identity and integrity of the confiscated dangerous drugs, warranting acquittal.

RULING

Yes. The ponencia granted accused-appellant’s appeal, a disposition with which Justice Leonen concurs. The separate concurring opinion emphasizes that the prosecution failed to establish an unbroken chain of custody. Critical links were compromised: the initial seizure of the box from the car on November 10 was not immediately witnessed by the required insulating witnesses (a representative from the media, the Department of Justice, and any elected public official), and the marking of the evidence was not done at the place of seizure. The subsequent search of the warehouse on November 11 also suffered from procedural lapses, as the inventory was not conducted immediately at the place of seizure but later at the police station, without the presence of the accused or their counsel. The prosecution did not offer justifiable grounds for these deviations. The integrity and evidentiary value of the seized items were not properly preserved. When there are unexplained gaps in the chain of custody that raise doubts about the identity of the corpus delicti, the accused must be acquitted based on reasonable doubt.