G.R. No. 239077 . March 20, 2019.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. GARRY BRIONES Y ESPINA, ACCUSED-APPELLANT.

FACTS

The prosecution’s evidence established that a buy-bust operation was conducted against accused-appellant Garry Briones y Espina on April 16, 2013, in Batangas City. Based on information from a confidential asset, a police team was formed with PO1 Carandang as the poseur-buyer. The team coordinated with the PDEA and barangay officials. At the designated location, the asset and Garry conversed, after which Garry handed a plastic sachet to the asset, who immediately passed it to PO1 Carandang. Garry was then arrested. The seized item was marked at the scene. The team then proceeded to the barangay hall where an inventory was conducted in the presence of a Department of Justice representative and a barangay councilor, but no media representative was present. The item was subsequently turned over to the crime laboratory, where it tested positive for methamphetamine hydrochloride.
The defense presented a starkly different version. Garry claimed he was merely eating at a carinderia when police officers, whom he recognized from a local cockpit, arrested him while they were allegedly looking for his neighbor. He denied any involvement in a drug transaction and asserted the charge was fabricated.

ISSUE

Whether the prosecution successfully proved the guilt of the accused beyond reasonable doubt for illegal sale of dangerous drugs, particularly in light of alleged non-compliance with the chain of custody requirements under Section 21 of Republic Act No. 9165 .

RULING

The Supreme Court ACQUITTED accused-appellant Garry Briones y Espina. The Court ruled that the prosecution failed to establish an unbroken chain of custody, which is crucial in proving the corpus delicti in drug cases. While the buy-bust team generally followed the procedure for marking, inventory, and laboratory examination, a critical deviation was not justified. The law requires the inventory to be conducted immediately after seizure and confiscation in the presence of the accused or his representative, a representative from the media and the Department of Justice (DOJ), and any elected public official. Here, the inventory was not conducted at the place of arrest but at the barangay hall. More importantly, the prosecution offered no justifiable reason for the absence of a media representative during the inventory, merely stating that they tried to call one but no one arrived.
The Court emphasized that while strict compliance may be excused upon a showing of justifiable grounds and a demonstration that the integrity and evidentiary value of the seized items were preserved, the prosecution bears the burden to explain such deviations. The police officers’ bare claim of an attempt to contact media, without detailing the earnest efforts undertaken, constituted a fatal procedural gap. This lapse, coupled with the failure to conduct the inventory at the seizure site, created reasonable doubt as to whether the item presented in court was the very same one seized from the accused. Consequently, the identity and integrity of the corpus delicti were compromised, warranting acquittal on the ground of reasonable doubt.