Case Digest (G.R. No. 254259)
Facts:
People of the Philippines charged Macmac Bangcola y Maki with illegal sale of dangerous drugs and illegal possession of dangerous drugs for acts committed on June 20, 2014 in Marikina City. At his arraignment on August 7, 2014, he pleaded not guilty, while his co-accused Salim Lala Pimba remained at large. After trial, the RTC, Branch 193 (Marikina City) convicted him on January 26, 2017, and the Court of Appeals affirmed on January 3, 2018.
The buy-bust involved SPO1 Deogracias Basang as poseur-buyer and marked P500.00 bills, with the sale evidenced by a heat-sealed plastic sachet (0.20 gram) marked as “MB-BUYBUST 6/20/14,” and thirteen additional sachets marked at the barangay hall (“MB-1 6/20/14” to “MB-13 6/20/14”). Inventory, marking, and photographing were conducted at the barangay hall, where Acuna and Barquilla were present, but no DOJ representative was there; appellant refused to sign the inventory. The forensic chemist PCI Libres later reported that the seized items tested positive for methamphetamine hydrochloride.
Issues:
- Whether appellant’s guilt for illegal sale and illegal possession of dangerous drugs was proven beyond reasonable doubt.
Ruling:
The Court granted the appeal, reversed the CA decision, and acquitted appellant for failure of the prosecution to prove guilt beyond reasonable doubt.
The Court ruled that the prosecution fatally failed to comply with the mandatory safeguards on chain of custody under Sec. 21 of R.A. No. 9165, particularly the absence of the required DOJ representative during the inventory, marking, and photographing of the seized drugs. It further found that the prosecution did not clearly establish all links in the chain of custody, including the transfer to the investigating officer, delivery to the forensic chemist, and safekeeping prior to presentation in court, creating serious doubt on the identity of the corpus delicti.
Ratio:
The Court held that the prosecution must establish with moral certainty the identity and integrity of the seized drugs as part of proving the elements of the charged offenses, and that the chain of custody rule exists to prevent doubts from tampering, alteration, or substitution of the evidence.
Applying Sec. 21 of R.A. No. 9165 (events occurred on June 20, 2014), the Court emphasized that the inventory and photography required the presence and signatures of mandated witnesses, including a DOJ representative, and that non-compliance could be excused only upon the prosecution’s proper recognition of lapses and proof that integrity was preserved. Because the prosecution offered no justification for the absence of the DOJ representative and failed to establish the remaining chain-of-custody links with sufficient evidence, the prosecution could not dispel reasonable doubt.
Doctrine:
- Conviction for illegal sale and illegal possession of dangerous drugs requires proof beyond reasonable doubt of the elements and, crucially, proof with moral certainty of the identity and integrity of the seized drug through the chain of custody rule.
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