People v. Mola
REITERATIONFacts
The Antecedents: Jaycent Mola y Selbosa a.k.a. "Otok" (Mola) was charged with illegal sale of Methamphetamine Hydrochloride (shabu) in violation of Section 5, Article II of Republic Act (R.A.) No. 9165. The Information alleged that on January 14, 2012, Mola sold and delivered a sachet of shabu weighing 0.04 grams in exchange for ₱500.00 to a poseur-buyer. Procedural History: Mola pleaded not guilty. The prosecution presented several police officers, including SPO4 Enrique Columbino, the poseur-buyer. SPO4 Columbino testified that he conducted a buy-bust operation where Mola sold him a sachet of shabu. The defense presented Mola, who denied the accusation and claimed he was at a store buying cigarettes when he was apprehended. The Regional Trial Court (RTC), Branch 44, Dagupan City, Pangasinan, convicted Mola and sentenced him to life imprisonment and a fine of ₱500,000.00. The Court of Appeals (CA) affirmed the RTC decision. Mola appealed to the Supreme Court. The Petition: Mola appealed to the Supreme Court, arguing that the buy-bust team failed to comply with Section 21, Article II of R.A. No. 9165 and that the prosecution failed to establish an unbroken chain of custody of the alleged seized dangerous drugs.
Issue(s)
Whether the Regional Trial Court gravely erred in convicting the accused-appellant despite the failure of the buy-bust team to comply with Section 21, Article II of R.A. No. 9165. Whether the prosecution failed to establish an unbroken chain of custody of the allegedly seized dangerous drugs.
Ruling
The Supreme Court reversed and set aside the decision of the Court of Appeals. Appellant Jaycent Mola y Selbosa a.k.a. "Otok" was acquitted for failure of the prosecution to prove his guilt beyond reasonable doubt. He was ordered immediately released from detention, unless confined for any other lawful cause.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the prosecution failed to provide a justifiable reason for non-compliance with the first link in the chain of custody, specifically the immediate marking of the dangerous drug seized from Mola, as required by Section 21(1) of R.A. No. 9165 and its Implementing Rules and Regulations (IRR). SPO4 Columbino's assertion that it was impractical to mark and inventory the shabu at the place of arrest because he was "only one" and "there were many persons" was deemed a hollow and unsubstantiated excuse, especially given his prior testimony that he was with companions during the operation. The Court emphasized that for the saving clause to apply, the prosecution must explain the reasons behind the procedural lapses, and that the integrity and value of the seized evidence had nonetheless been preserved, with justifiable grounds proven as a fact, which was not done in this case. The absence of the required witnesses from the Department of Justice (DOJ), the local government, and the media during the marking and inventory was also fatal, as the prosecution failed to allege or prove their unavailability or any threats to safety. The Court rejected the notion that the presumption of regularity could cure these inexcusable lapses, asserting that this presumption is never stronger than the presumption of innocence in favor of the accused, as reiterated in Casona v. People (G.R. No. 179757) and People v. Andaya. On Issue 2: The Supreme Court held that the prosecution failed to establish an unbroken chain of custody of the allegedly seized dangerous drugs, thus creating reasonable doubt as to the corpus delicti. While a civilian witness, Cayabyab, saw the seizure of the sachet, he did not witness the actual marking and physical inventory of the items, which SPO4 Columbino admitted was done at the police precinct without Cayabyab's presence. Cayabyab's only involvement was signing the confiscation/inventory receipt at his store, a process detached from the actual inventory and without verification of the seized item's identity at that point. Furthermore, the prosecution failed to demonstrate another crucial link in the chain of custody by dispensing with the forensic chemist's testimony without a stipulation covering the integrity of the seized item from its receipt by the laboratory until its presentation in court. The forensic chemist's testimony was limited to the positive result of the examination, but there was no certification that the substance tested was the same one recovered from Mola, nor was the turnover and submission of the marked illegal drugs from the forensic chemist to the court properly established, as clarified in cases like People v. Gayoso (G.R. No. 206590) and People v. Abelarde (G.R. No. 215713). This failure left critical gaps, raising doubt whether the corpus delicti presented in court was indeed the same item confiscated from Mola at the time of his arrest.
Main Doctrine
The prosecution must prove beyond reasonable doubt that the illegal drugs presented in court are the same illegal drugs seized from the accused, establishing an unbroken chain of custody. Failure to comply with the procedural requirements of Section 21 of R.A. No. 9165, without justifiable grounds and without preserving the integrity and evidentiary value of the seized items, warrants acquittal.