G.R. No. 231007 , July 1, 2019
People of the Philippines, Plaintiff-Appellee vs. Antonio Martin y Ison, Accused-Appellant

FACTS

The prosecution alleged that a buy-bust operation was conducted against appellant Antonio Martin based on a tip from a confidential informant. The informant, acting as poseur-buyer, used marked money to purchase a plastic sachet of suspected shabu from appellant at Lacson Colleges in San Leonardo, Nueva Ecija. Arresting officers PO3 Gavino and PO2 Songalia, positioned nearby, apprehended appellant after a pre-arranged signal. The seized item was marked “ANG-1” at the police station in the presence of appellant, barangay officials, and media representatives, before being submitted to the crime laboratory, where it tested positive for methamphetamine hydrochloride.
Appellant denied the charges, claiming he was framed. He testified that he was merely urinating outside his residence when he was approached by a man later identified as an asset, who showed him a plastic sachet and demanded information about a certain “Paolo.” When he refused, he was handcuffed, arrested, and brought to the police station where his money was taken. He insisted no illegal sale occurred.

ISSUE

Whether the prosecution established appellant’s guilt for illegal sale of dangerous drugs beyond reasonable doubt, particularly by complying with the chain of custody rule under Section 21, Article II of Republic Act No. 9165 .

RULING

The Supreme Court ACQUITTED appellant. The prosecution failed to prove an unbroken chain of custody, which is crucial in drug cases to establish the identity and integrity of the corpus delicti. The Court found glaring gaps in the procedure. First, while the marking of the seized plastic sachet with “ANG-1” was done at the police station, the arresting officer, PO3 Gavino, admitted he did not immediately mark it at the place of arrest. This departure from the procedure required by law was not justified.
Second, and more critically, the required witnesses during the physical inventory and photographing were not present at the time of seizure or arrest as mandated. The law requires the presence of an elected public official, a Department of Justice representative, and a media representative immediately after seizure and confiscation. The prosecution’s own evidence showed that the barangay councilor and media representatives were only present later at the police station. The prosecution offered no credible explanation for this deviation, failing to prove that earnest efforts were made to secure their presence at the scene. These breaches in the chain of custody procedure created reasonable doubt as to whether the item presented in court was the same one allegedly seized from appellant. Consequently, the presumption of regularity in the performance of official duty was overturned, warranting acquittal.