Case Digest (G.R. No. 231792)
Facts:
An Information filed before the RTC of Dagupan City, Branch 44 charged Alvin Jugo y Villanueva with Illegal Sale of Dangerous Drugs under Section 5, Article II of RA 9165 for selling one (1) heat-sealed plastic sachet of methamphetamine hydrochloride (shabu) weighing 0.101 gram to an undercover police officer during a buy-bust operation on August 5, 2011 in San Fabian, Pangasinan. The RTC convicted Jugo, finding the elements of illegal sale proved, and the CA affirmed, rejecting his chain-of-custody challenges and holding the police arrest and evidence handling substantially complied with the required procedure.
On appeal, Jugo argued that there were material deviations in the chain of custody, including that marking and related procedures were not done immediately after arrest and confiscation, were not conducted in the presence of the required witnesses, and that there were discrepancies regarding from whom the sachet was seized as reflected in the testimony and the documents.
Issues:
- Whether Jugo’s conviction for illegal sale of dangerous drugs under Section 5, Article II of RA 9165 should be upheld despite alleged lapses in the chain of custody.
- Whether the prosecution justified the non-compliance with the required procedure under Section 21, Article II of RA 9165, as amended by RA 10640, and its IRR, so as to preserve the integrity and evidentiary value of the seized drug.
Ruling:
The Supreme Court GRANTED the appeal, REVERSED the CA decision, and ACQUITTED Jugo for failure of the prosecution to prove guilt beyond reasonable doubt. It ordered the Director of the Bureau of Corrections to cause Jugo’s immediate release unless lawfully held for another reason.
Ratio:
The Court held that in illegal sale cases, the prosecution must establish the identity of the prohibited drug with moral certainty through an unbroken chain of custody from seizure to presentation in court. It emphasized that while strict compliance with the Section 21 procedure may be excused under justifiable grounds, the prosecution must expressly explain the lapses and prove that the integrity and evidentiary value of the seized item were nonetheless preserved.
Applying these standards, the Court found substantial, unjustified gaps. It noted that the preparation of the Confiscation Receipt and the taking of photographs were not shown to have been done in the presence of the accused or his representative, an elected public official, and a representative from the DOJ or the media, contrary to Section 21, Article II of RA 9165, as amended by RA 10640. It further observed that witnesses’ testimonies and the documents did not corroborate the prosecution’s claim that these required witnesses were present during the inventory-related procedure, and no credible justification for the deviations was offered. Because these breaches compromised the integrity and evidentiary value of the corpus delicti, acquittal followed.
Doctrine:
- For conviction of illegal sale of dangerous drugs, the prosecution must establish the identity of the prohibited drug with moral certainty through an unbroken chain of custody.
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