G.R. No. 245486 - People vs. De Motor y Dantes

Two Informations were filed before the Regional Trial Court (RTC) of Lipa City, Batangas, accusing Ronald Jaime De Motor y Dantes in two separate cases for violations of Republic Act (RA) 9165.
Criminal Case No. 0461-2012 pertained to the crime of Illegal Sale of Dangerous Drugs under Section 5, Article II of RA 9165, while Criminal Case No. 0462-2012 involved Illegal Possession of Dangerous Drugs under Section 11, Article II of the same law.

On August 13, 2012, around 3:00 in the afternoon, police officers, acting on information from a civilian asset, conducted a buy-bust operation at a Jollibee branch in Barangay Mataas na Lupa, Lipa City.
During the operation, officers recovered a total of nine sachets containing dried marijuana leaves from the accused.
After the apprehension, police officers frisked the accused and marked the recovered items, and subsequently took him to the police headquarters where the drugs were inventoried and photographed.
These procedures were conducted in the presence of the accused, Barangay Captain Pablo V. Levita, and Michael Dominic Flores, a representative from a local radio station.

The seized items were transported to the Philippine National Police-Batangas Provincial Crime Laboratory.
A forensic examination confirmed that the substance tested positive for marijuana, thereby linking the recovered items to dangerous drugs under RA 9165.
The inventory and photography of the seized items were meant to establish the chain of custody and preserve the integrity of the evidence.

In its Decision dated June 23, 2017, the RTC found all elements of the crimes charged to be proved beyond reasonable doubt and convicted the accused.
The concessions included:

In Criminal Case No. 0461-2012, a sentence of life imprisonment and a fine of P500,000.00.
In Criminal Case No. 0462-2012, imprisonment for a period of twelve (12) years and one (1) day to fourteen (14) years and a fine of P300,000.00.

The trial court heavily relied on the testimonies of the prosecution’s witnesses, affirming the sufficiency of the evidence presented.

The accused-appellant challenged his conviction on appeal, arguing the testimony inconsistencies of the prosecution’s witnesses were significant.
A crucial point raised was the alleged non-compliance with the chain of custody rule: particularly, the failure to have a Department of Justice (DOJ) representative present during the inventory and photography of the seized drugs.
The Court of Appeals (CA), in its Decision dated September 4, 2018, maintained that the minor discrepancies in witness statements were trivial and the chain of custody requirement had been substantially met, thereby affirming the RTC’s decision.

The Supreme Court reviewed the procedural lapses regarding the chain of custody, focusing on the absence of the mandated DOJ representative during the evidentiary procedures.
It examined whether such deviation, although seemingly minor, compromised the integrity of the seized items—constituting the corpus delicti in drug cases.

Whether the failure to have a DOJ representative during the inventory and photography of the seized items constitutes a failure to comply with the chain of custody requirements under RA 9165.
Whether such non-compliance undermines the evidentiary integrity of the recovered drugs to the point that the State cannot establish the identity of the dangerous drug with moral certainty.
Whether the minor inconsistencies in the prosecution’s witness testimonies, as argued by the defense, are substantial enough to negate the conviction.
Whether the justifiable ground for the non-compliance with the required witness presence was adequately established by the prosecution.