Title
Matabilas vs. People
Case
G.R. No. 243615
Decision Date
Nov 11, 2019
A man acquitted after Supreme Court ruled prosecution failed to justify the absence of a DOJ representative during drug inventory, breaching chain of custody rules.
drug trafficking
mandatory witness requirement
chain of custody rule

Case Summary (G.R. No. 243615)

Factual Background: The Buy-Bust, Seizure, and Alleged Drug Evidence

The prosecution alleged that on September 6, 2012 at around 5:00 in the afternoon, police officers of the Kidapawan City Police Station, acting on a tip from a confidential informant, conducted a buy-bust operation against petitioner at Villanueva Subdivision in Kidapawan City, Cotabato. During the operation, the officers recovered from petitioner one plastic sachet containing 0.05 gram of a white crystalline substance.

After the arrest, the police officers supposedly immediately conducted marking, inventory, and photography of the seized item in the presence of petitioner and two alleged witnesses: Ruel C. Anima, a kagawad of Barangay Poblacion, Kidapawan City, and Romnick Cabaron, a member of radio station DXND. The seized item was then brought to the Philippine National Police Provincial Crime Laboratory of the Province of Cotabato, where a chemical examination tested positive for methamphetamine hydrochloride, commonly known as shabu.

Defense Theory

Petitioner denied the accusation. He claimed that on the date and time of the alleged incident, he was in Kidapawan City looking for potential customers of coconuts when two police officers approached him, conducted a purportedly futile search on his person and motorcycle, and then forcibly brought him to the store of Clifton Cris Simene. According to petitioner, the police officers falsely made it appear that a P500.00 bill and a sachet containing white crystalline substance were recovered from his possession.

RTC Conviction and Findings on the Elements and Chain of Custody

In a Judgment dated November 12, 2014, the RTC found petitioner guilty beyond reasonable doubt of Illegal Sale of Dangerous Drugs. The RTC gave weight to the prosecution witnesses and held that the elements of the offense had been established. It likewise ruled that there was proper compliance with the chain of custody rule, crediting the prosecution evidence as to the identity and integrity of the seized drug.

The RTC imposed the penalty of life imprisonment and ordered petitioner to pay a fine of P500,000.00. Petitioner’s motion for reconsideration was denied by an Order dated September 2, 2015.

Proceedings in the Court of Appeals

Petitioner appealed to the CA. He argued that the trial court erred in appreciating the prosecution witnesses because their testimonies allegedly contained glaring inconsistencies that indicated fabrication. He also maintained that the RTC failed to give probative weight to the defense witnesses. Further, he asserted that the arresting officers violated the mandatory requirements of the chain of custody rule, specifically by failing to secure the presence of a representative from the Department of Justice (DOJ) during the inventory procedure.

In its Decision dated March 22, 2018, the CA affirmed petitioner’s conviction. It considered the alleged inconsistencies as trivial and not affecting the outcome. It also ruled that petitioner failed to prove that the buy-bust was fabricated. As to the chain of custody, the CA found substantial compliance because the prosecution allegedly established the whereabouts of the seized drugs from seizure to their presentation in court.

Petitioner’s motion for reconsideration was denied in a Resolution dated October 17, 2018, prompting the petition to the Supreme Court.

Procedural Treatment in the Supreme Court

At the outset, the Court observed that petitioner committed a procedural lapse by elevating the case through a petition for review on certiorari under Rule 45 of the Rules of Court. It noted that under Section 13(c), Rule 124 of the Rules, where the penalty imposed is life imprisonment, the appeal should be made by a notice of appeal. Nevertheless, in the interest of substantial justice, the Court treated the petition as an ordinary appeal to resolve the substantive issues.

Issues Raised and the Court’s Review Approach

Petitioner sought acquittal on three grounds: first, alleged serious and glaring inconsistencies in the prosecution witnesses’ testimonies; second, alleged error by the courts a quo in failing to appreciate defense testimony; and third, failure of the arresting officers to comply with the mandatory witness requirement under the chain of custody rule, particularly the absence of a DOJ representative during inventory.

On the first two grounds, the Court held them untenable. It reiterated the well-entrenched rule that findings of fact of the trial court, including credibility determinations and the calibration of testimony, are accorded great respect and are generally conclusive absent a showing that the trial court overlooked significant matters affecting the outcome. It further stated that inconsistencies in witness testimony do not necessarily impair credibility if there is consistency on the principal occurrence and the identity of the accused.

However, the Court found that petitioner’s third argument revealed a specific and material defect that the courts a quo left unaddressed—an unjustified deviation from the chain of custody witness requirement.

Chain of Custody Framework and the Need to Prove Identity with Moral Certainty

In prosecutions under RA 9165 for Illegal Sale and/or Illegal Possession of Dangerous Drugs, the Court emphasized that the dangerous drug’s identity must be established with moral certainty, because the drug forms an integral part of the corpus delicti. Failure to prove the integrity of the corpus delicti means the State fails to establish guilt beyond reasonable doubt, warranting acquittal.

To establish drug identity with moral certainty, the prosecution must account for each link of the chain of custody from seizure to presentation in court. Under the law, the marking, physical inventory, and photography must be conducted immediately after seizure and confiscation. The Court recognized that while failure to mark at the place of arrest does not automatically invalidate the evidence, marking at the nearest police station or office is acceptable.

The Court then focused on the witness requirement. It explained that the law mandates the inventory and photography be done in the presence of the accused or the person from whom the items are seized, or his representative or counsel, and certain required witnesses. Depending on whether the conduct is before or after the amendment introduced by RA 10640, the required witnesses differ. For purposes relevant to the case, the Court treated the witness requirement as involving the presence of an elected public official and either a representative from the National Prosecution Service or the media, and it discussed that the DOJ witness requirement governed prior to the amendment.

The Court stressed the rationale for strict compliance: the required witnesses are meant primarily to ensure the chain of custody and to remove suspicion of switching, planting, or contamination. Though it acknowledged a saving clause in the IRR of RA 9165, later adopted in RA 10640, the prosecution must still explain the procedural lapses and prove justifiable grounds. The Court cannot presume such grounds or their existence.

Deviation From the Mandatory Witness Requirement: Absence of the DOJ Representative

The Court found an unjustified deviation from the witness requirement. It held that the inventory and photography were not witnessed by a representative of the DOJ. This was evident from the Inventory of Confiscated Drugs/Seized which showed only Anima as the elected public official and Cabaron as the media representative.

The Court also relied on testimonial admissions. In Anima’s direct examination, he stated that the only civilian witnesses present besides himself were Cabaron. In the testimony of arresting officers, PO1 Rolando Cabalinan, Jr. and PO1 Armand Bada, the Court noted they did not acknowledge or explain the absence of a DOJ representative. PO1 Cabalinan confirmed that the signatures and witness participatio

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