GR 254208; (August, 2022) (Digest)
G.R. No. 254208, August 16, 2022
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. MA. DEL PILAR ROSARIO C. CASA, ACCUSED-APPELLANT.
FACTS
Accused-appellant Ma. Del Pilar Rosario C. Casa was charged with illegal sale and possession of dangerous drugs. A buy-bust operation was conducted on July 21, 2015, in Dumaguete City. PO1 Darelle Jed Delbo acted as the poseur-buyer and purchased one sachet of shabu from the accused-appellant for PHP 500.00. Upon her arrest, eleven more sachets were confiscated from a plastic container in her possession. The seized items were marked at the scene. However, the physical inventory and photographing of the evidence were not conducted at the place of arrest or the nearest police station. The apprehending team decided to conduct the inventory at their Special Operations Group (SOG) office for purported security reasons. The required witnesses—a barangay official, a media representative, and a Department of Justice representative—were only present at the SOG office and signed the inventory receipt there.
ISSUE
Whether the prosecution successfully established the integrity and evidentiary value of the seized dangerous drugs, considering the deviation from the chain of custody rule under Section 21 of Republic Act No. 9165, as amended.
RULING
No. The Supreme Court REVERSED the conviction and ACQUITTED the accused-appellant. The Court emphasized that in prosecutions for illegal drugs, the State must prove an unbroken chain of custody to establish the identity and integrity of the corpus delicti. The law mandates that the physical inventory and photographing of seized items be conducted immediately after seizure and confiscation, either at the place of arrest or the nearest police station, in the presence of the accused and the required insulating witnesses. Here, the police offered no justifiable ground for transferring the inventory to the SOG office. The witnesses were not present at the arrest scene but were merely summoned to the office, which contravened the witness requirement’s purpose of insulating the procedure from police influence. This constituted a substantial gap in the chain of custody. The prosecution failed to provide a credible explanation for this procedural lapse and did not demonstrate that the integrity and evidentiary value of the seized items were preserved despite the deviation. Consequently, the identity of the corpus delicti was compromised, creating reasonable doubt. The Court reiterated that strict compliance with Section 21 is required, and any divergence must be justified; otherwise, it warrants the accused’s acquittal.