Title
People vs. Edwin Cordova y Manalastas, Jayson Taladua y Barbarrra, Mary Antonette Del Rosario y Tamondong, and Jaime Cordova y Manalastas
Case
G.R. No. 267265
Decision Date
Jan 24, 2024
Accused acquitted due to broken chain of custody in drug buy-bust operation; procedural lapses compromised evidence integrity, leading to reasonable doubt.

Case Summary (G.R. No. 72306)

Key Dates and Case Numbers

Alleged offenses/operative facts: January 17, 2019.
Arraignment and pre-trial stipulation: February 11, 2019.
RTC Joint Judgment (Branch 79, Quezon City): May 29, 2019 — Criminal Case Nos. R‑QZN‑19‑01905‑CR, R‑QZN‑19‑01906‑CR, R‑QZN‑19‑01907‑CR, R‑QZN‑19‑01908‑CR and R‑QZN‑19‑01909‑CR to R‑QZN‑19‑01912‑CR.
Court of Appeals Decision affirming RTC: November 11, 2022 (CA‑G.R. CR HC No. 13028).
Supreme Court Decision under review: January 24, 2024 (appeal under Rule 122).

Charges and Allegations

Edwin and Taladua (with Jaime and Del Rosario) were charged in multiple Informations for: (a) violation of Section 5, Article II (illegal sale of methamphetamine hydrochloride) — several counts alleging sale of individually marked heat‑sealed plastic sachets containing specified gram weights of white crystalline substance; and (b) violation of Section 11, Article II (illegal possession of the same marked sachets). Specific allegations recited the markings on sachets and stated gram weights (e.g., BB‑LT‑EC 01‑17‑19 — 0.07 g; BT‑AJT 01‑17‑19 — 0.10 g; FRB‑JC 01‑17‑19 — 0.08 g; MAS‑MAD 01‑17‑19 — 0.07 g).

Procedural Posture and Pre‑trial Stipulation

All four accused pleaded not guilty at arraignment. Parties stipulated to the forensic chemist PCI Bernardo Roque’s qualifications and laboratory examination results: Roque received five heat‑sealed sachets (with signatures), performed qualitative testing, found positive results for methamphetamine hydrochloride, issued Chemistry Report No. D‑180‑19, marked and sealed the specimens as “D‑180‑19 BRR” and turned the sealed items over to evidence custodian PO2 Junia Tuccad, who stored them in the QCPD Crime Laboratory evidence room and later produced them in court on subpoena.

Prosecution’s Case and Evidence

The prosecution’s case rested on buy‑bust operations conducted on January 17, 2019. Testimony of PO1 Leehero Torres (poseur buyer) and other arresting officers related the following: a confidential informant identified “alias Bong” (pointing to Edwin) as selling shabu; the team conducted a buy‑bust with PO1 Torres as poseur buyer and prearranged signal (towel on right shoulder) upon consummation; at the alleged transaction PO1 Torres gave buy‑bust money to Edwin and received a sachet; Edwin purportedly handed sachets to Taladua, Jaime and Del Rosario when they arrived; after PO1 Torres signaled, back‑up officers effected arrests and seized sachets and the buy‑bust money; the seized items were allegedly marked, inventoried, photographed and witnessed by Barangay Captain Leo Garra and media representative Christopher Yu; the seized items were submitted to the QCPD Crime Laboratory where PCI Roque conducted testing and issued the chemistry report.

Defense Version

Each accused testified to contradict the buy‑bust narrative: Taladua and Jaime claimed arrests occurred at different times and places (inside Edwin’s Auto Supply or their rooms), with civilian‑clothed officers forcibly entering, handcuffing and transporting them to a van and to Police Station 5; Edwin claimed arrest at his Auto Supply, denied being “Bong,” described being mauled and shown sachets at a 7‑Eleven after being brought to the station; all denied knowledge or possession of the marked sachets and alleged that evidence was laid out later at the 7‑Eleven. The defense emphasized lack of immediate marking, irregularities in inventory and late arrival of insulating witnesses.

RTC Judgment

The Regional Trial Court rendered a Joint Judgment (May 29, 2019) finding Edwin guilty beyond reasonable doubt of certain counts of Section 5 (illegal sale) and Section 11 (illegal possession) and sentencing him to life imprisonment and additional imprisonment on possession counts; it found Taladua guilty of Section 11 in a count and ordered fines. Jaime was acquitted in relevant counts; Del Rosario later moved to and was allowed to plea bargain, pleading guilty to Section 12 and being sentenced accordingly before the RTC’s decision on others.

Court of Appeals Ruling

The Court of Appeals affirmed the RTC’s Joint Judgment on November 11, 2022, concluding that the prosecution had established compliance with chain‑of‑custody requirements and had proven the integrity of the corpus delicti beyond reasonable doubt.

Issue Presented on Appeal to the Supreme Court

Whether the Court of Appeals erred in upholding the convictions of Edwin and Taladua for violations of Sections 5 and 11, Article II of R.A. No. 9165 — particularly whether the prosecution proved the unbroken chain of custody required to establish the identity and integrity of the seized drugs.

Legal Standard — Chain of Custody Under R.A. No. 9165 (as amended)

The Supreme Court reiterated the governing rule that to convict for illegal sale/possession the prosecution must establish with moral certainty that the allegedly confiscated drug is the same item presented in court. Chain of custody under Section 21, Article II of R.A. No. 9165 (as amended by R.A. No. 10640) prescribes recorded, authorized movements of seized items from seizure and marking; turnover to the investigating officer; turnover to the forensic chemist for examination; and submission by the chemist of the marked items to the court. Jurisprudence requires immediate marking, inventory and photographing at the place of seizure (or in nearest police station only when practicable) and the presence of insulating witnesses (elected official and NPS representative or media representative after RA 10640), unless justifiable grounds for deviation are shown and the integrity and evidentiary value of the items are preserved.

Application of the Legal Standard to the Facts — First Link Violation

The Supreme Court found that the prosecution failed to establish the first and crucial link (seizure, marking and immediate inventory) in the chain of custody. Testimony of PO1 Torres and PO1 Ty showed that the insulating witnesses (Barangay Captain Garra and media representative Yu) were not present at or immediately near the place of arrest; they were called only after the arrests. The arrest and booking sheet indicated arrests at about 11:20 p.m., while Barangay Captain Garra arrived at approximately 11:30 p.m. and the media representative at approximately 11:45 p.m., producing at least a 25‑minute interval between seizure/arrest and inventory/marking. The Court held that this delay was an unjustified deviation from the immediate‑marking and immediate‑inventory requirement; because the inventory and photographing were not conducted “immediately after seizure and confiscation,” the prosecution’s evidence on preservation of integrity was suspect.

Lack of Justification and Failure to Invoke Saving Proviso

Although Section 21 contains a saving proviso allowing noncompliance if justifiable grounds exist and the integrity of the seized items was preserved, the Supreme Court emphasized that the prosecution and arresting officers must acknowledge and justify any lapses. In this case, no justifiable ground for the delay was offered and no affirmative proof was presented to show preservation of evidentiary integrity. That absence of explanation undermined the presumption of regularity in official acts and raised reasonable doubt regarding the iden

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