People v. Hernandez
REITERATIONFacts
The Antecedents: Accused-appellant Donato Hernandez was charged with Illegal Sale and Illegal Possession of Dangerous Drugs under Sections 5 and 11, Article II of Republic Act No. 9165. The charges stemmed from a buy-bust operation conducted on September 16, 2017, where police officers allegedly purchased 0.12 grams of methamphetamine hydrochloride (shabu) and recovered an additional 11.69 grams from his person and house. Procedural History: The Regional Trial Court (RTC), Branch 36, Calamba City, Laguna, found Donato guilty beyond reasonable doubt and sentenced him to life imprisonment and a fine of Php500,000.00 for each offense. The Court of Appeals (CA) affirmed the RTC's decision. Donato appealed to the Supreme Court. The Petition: Donato argued that the prosecution failed to strictly comply with the chain of custody rule, citing deficiencies in the marking of seized drugs, the inventory, the turnover to the investigating officer, and the handling of specimens by the forensic laboratory. He claimed the illegal drugs were planted.
Issue(s)
Whether the prosecution proved Donato's guilt for violation of Sections 5 and 11, Article II of RA 9165 beyond reasonable doubt, and whether the chain of custody of the seized dangerous drugs was sufficiently established.
Ruling
The Supreme Court granted the appeal, reversed and set aside the decision of the Court of Appeals, and acquitted Donato C. Hernandez of the crimes charged due to 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 the issue of whether the prosecution proved Donato's guilt beyond reasonable doubt and the chain of custody: The Court ruled in the negative. While the first two links in the chain of custody (seizure and marking, and turn-over to the investigating officer) were substantially complied with, the prosecution failed to demonstrate observance of the third and fourth links. Specifically, the testimony of PO2 Comia, who supposedly received the drug specimens at the crime laboratory, was absent. This failure to present PO2 Comia left unanswered questions regarding the condition of the contraband when received and the precautions taken to ensure its integrity. Furthermore, the stipulated testimony of the forensic chemist, PCI Huelgas, did not cover the handling of the specimens from receipt until presentation in court, nor the method of analysis used. This created a missing link from the time the drugs were in PCI Huelgas' hands to their submission to the court, failing to convincingly show that the specimens submitted were the same ones recovered from Donato. The Court emphasized that the integrity of the corpus delicti must be proven with moral certainty. The lapses in the chain of custody fatally compromised the integrity and evidentiary value of the seized illegal drugs, thus warranting acquittal. The presumption of regularity in the performance of official duties cannot prevail over the presumption of innocence when challenged by evidence of a flawed chain of custody.
Main Doctrine
The prosecution failed to prove the integrity of the corpus delicti due to fatal lapses in the chain of custody, specifically in the third and fourth links, warranting the acquittal of the accused despite the presumption of regularity in the performance of official duties.