G.R. No. 227309 - People vs. Carlit y Gawat

PO3 Christian Carvajal, assigned at Dagupan City Police Station, was tasked on February 26, 2011, to serve as a poseur buyer in a buy-bust operation targeting Jocelyn Carlit.
The operation was initiated based on information that Carlit was engaged in illegal activities, specifically involving the sale of dangerous drugs.

Around 2:00 p.m., Carvajal, accompanied by a civilian asset, engaged Carlit in the squatters area at Highlander, Mayombo District, Dagupan City.
Carlit allegedly handed over a sachet containing shabu in exchange for marked buy-bust money consisting of five 100-peso bills.
After receiving the drug, Carvajal identified himself as a police officer and arrested Carlit, recovering both the sachet of shabu and the marked money.

At the police station, the seized shabu was recorded in the police blotter and marked with the officer’s initials.
A confiscation receipt was prepared and signed by a representative from the Department of Justice, albeit without media presence.
The specimen weighing 0.07 gram was handled exclusively by PO3 Carvajal until it reached the PNP Crime Laboratory, where PSI Myrna Malojo TodeAo examined it.
The forensic chemist’s Initial Laboratory Report and Final Chemistry Report confirmed that the substance tested positive for methamphetamine hydrochloride.
The evidence was then turned over to the evidence custodian, PO2 Manuel, marking a critical link in the chain of custody.

Carlit was charged with illegal sale of dangerous drugs under Section 5 of R.A. 9165.
The RTC’s trial proceedings involved the testimonies of two key witnesses: PO3 Carvajal, who narrated the encounter and seizure, and forensic chemist PSI TodeAo, who detailed the laboratory examination and handling of the specimen.
Despite Carlit’s denial of selling shabu, the RTC ruled, in its September 20, 2013 Decision, that the evidence established her guilt beyond reasonable doubt, sentencing her to life imprisonment and imposing a fine of P500,000.00.

Carlit raised defenses including the claim of illegal arrest and denial of the sale, while also questioning the integrity of the chain of custody due to procedural lapses.
The CA, in its August 20, 2015 Decision, affirmed the RTC ruling, denying her appeal despite the issues raised regarding coordination with the Philippine Drug Enforcement Agency, immediate marking of the seized item, and absence of proper inventory witnesses.

Carlit filed an appeal with the Supreme Court challenging her conviction on the grounds that the prosecution failed to prove an unbroken chain of custody of the seized drug.
The Supreme Court identified deficiencies including the absence of testimony from the evidence custodian, PO2 Manuel, and non-compliance with procedural requirements under Section 21 of R.A. 9165 regarding immediate marking and inventory protocols.
Emphasizing the necessity of proving every link in the chain of custody with moral certainty, the Court found that the prosecution had not demonstrated that the integrity and identity of the dangerous drug were preserved.
As a result, the Court granted the appeal, reversed the CA Decision, and acquitted Carlit, directing her immediate release unless held for another lawful cause.

Whether the prosecution was able to establish an unbroken chain of custody for the seized specimen of dangerous drugs.

Did the handling and marking procedures comply with the requirements of Section 21 of R.A. 9165 as amended by R.A. 10640?
Was the absence of testimony from the evidence custodian (PO2 Manuel) detrimental to establishing the integrity of the chain of custody?

Whether the procedural lapses—such as failure to conduct the inventory with an elected public official and a representative of the National Prosecution Service or the media—undermine the evidentiary value of the specimen.

Could these lapses provide justifiable grounds for the violation of mandatory procedures under the law?
Were the deviations from established protocol sufficient to cast reasonable doubt on the authenticity of the corpus delicti?

Whether the courts below correctly found the accused guilty despite these irregularities in evidence handling and procedural compliance.