Title
Badio y Dicampung vs. People
Case
G.R. No. 236023
Decision Date
Feb 20, 2019
Badio acquitted due to prosecution's failure to justify absence of required witnesses during drug inventory, compromising evidence integrity.
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Case Digest (G.R. No. 236023)

Facts:

Background of the Case
This case involves a petition for review on certiorari filed by Macacuna Badio y Dicampung (Badio), challenging his conviction for Illegal Possession of Dangerous Drugs under Section 11, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). The case originated from an Information filed before the Regional Trial Court (RTC) of Manila, Branch 2, charging Badio with the said crime.

The Arrest and Seizure
On August 24, 2013, the Station Anti-Illegal Drugs Special Operation Task Unit of the Moriones, Tondo Police Station 2 received a tip about an illegal drug transaction near a specified vehicle along Antonio Rivera Street corner CM. Recto Avenue, Manila. A team was formed to conduct surveillance and effect arrests if necessary. At around 8:30 PM, the team observed Badio approaching the vehicle and conversing with its passengers. Police Officer 3 Roman Jimenez (PO3 Jimenez) saw Badio showing two transparent plastic sachets containing a white crystalline substance to the passengers. When the team approached, Badio threw the sachets, but PO3 Jimenez recovered them and arrested Badio. A body search revealed another plastic sachet on Badio. The seized items were marked, photographed, and inventoried in the presence of Badio and a media representative. The items were later confirmed to contain 5.01 grams of methamphetamine hydrochloride (shabu).

Badio’s Defense
Badio denied the charges, claiming that he was forcibly taken by unidentified men who introduced themselves as police officers while he was inside a vehicle in Baclaran. He was later informed that he was being charged with Illegal Possession of Dangerous Drugs.

RTC and CA Decisions
The RTC found Badio guilty beyond reasonable doubt and sentenced him to 12 years and 1 day to 17 years and 4 months imprisonment, with a fine of P300,000. The Court of Appeals (CA) affirmed the conviction but modified the penalty to 20 years and 1 day imprisonment and a fine of P400,000. The CA held that the prosecution established an unbroken chain of custody over the seized drugs, despite the absence of a DOJ representative and an elected public official during the inventory.

Issue:

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Ruling:

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Ratio:

  1. Chain of Custody and Integrity of Evidence
    In cases involving illegal possession of dangerous drugs, the identity and integrity of the seized drugs must be established with moral certainty. The prosecution must account for each link in the chain of custody, from seizure to presentation in court. Non-compliance with the chain of custody rule, particularly the witness requirement, may render the evidence inadmissible unless the prosecution provides a justifiable reason for the lapse and proves that the integrity of the evidence was preserved.

  2. Witness Requirement
    The law requires that the inventory and photography of seized items be conducted in the presence of the accused or their representative, as well as specific witnesses: a representative from the media, the DOJ, and an elected public official (prior to the amendment of RA 9165 by RA 10640). The presence of these witnesses ensures the integrity of the evidence and prevents allegations of switching, planting, or contamination.

  3. Justifiable Grounds for Non-Compliance
    While strict compliance with the chain of custody rule is required, deviations may be excused if the prosecution proves that there was a justifiable ground for non-compliance and that the integrity of the evidence was preserved. Mere statements of unavailability of witnesses, without genuine efforts to secure their presence, are insufficient to justify non-compliance.

  4. Application to the Case
    In this case, the prosecution failed to justify the absence of a DOJ representative and an elected public official during the inventory. There was no evidence of genuine efforts to secure their presence. As a result, the integrity and evidentiary value of the seized drugs were compromised, warranting Badio’s acquittal.

Conclusion:

The Supreme Court emphasized the importance of strict compliance with the chain of custody rule in drug cases. The failure to justify deviations from the rule, particularly the absence of required witnesses, compromises the integrity of the evidence and warrants the acquittal of the accused.


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