People v. Cordova
REITERATIONFacts
The Antecedents: The case stemmed from eight (8) separate Informations filed before the Regional Trial Court (RTC) charging Edwin Cordova y Manalastas (Edwin) and Jayson Taladua y Barbarra (Taladua), along with Jaime Cordova y Manalastas (Jaime) and Mary Antonette Del Rosario y Tamondong (Del Rosario), with violations of Sections 5 (Illegal Sale) and 11 (Illegal Possession) of Republic Act (R.A.) No. 9165, the Comprehensive Dangerous Drugs Act of 2002. The alleged offenses occurred on January 17, 2019, in Quezon City. The prosecution presented evidence from a buy-bust operation where Edwin was allegedly caught selling methamphetamine hydrochloride. Subsequently, Taladua, Jaime, and Del Rosario arrived, and Edwin allegedly handed them sachets of the same substance. The police apprehended all four, seizing several sachets of what was later confirmed to be methamphetamine hydrochloride. During the proceedings, Del Rosario entered into a plea bargain for a lesser offense and was convicted of violation of Section 12, Article II of R.A. No. 9165. Edwin and Taladua were convicted by the RTC for violations of Sections 5 and 11, Article II of R.A. No. 9165. Jaime was acquitted. Procedural History: The RTC rendered a Joint Judgment finding Edwin and Taladua guilty beyond reasonable doubt for violations of Sections 5 and 11, Article II of R.A. No. 9165. Edwin was convicted in Criminal Case Nos. R-QZN-19-01905-CR, R-QZN-19-01906-CR, and R-QZN-19-01909-CR, while Taladua was convicted in Criminal Case No. R-QZN-19-01910-CR. Jaime was acquitted in Criminal Case No. R-QZN-19-01911-CR. Edwin and Taladua appealed their conviction to the Court of Appeals (CA). The CA affirmed the RTC's Joint Judgment. Edwin and Taladua then appealed to the Supreme Court. The Petition: Accused-appellants Edwin Cordova y Manalastas and Jayson Taladua y Barbarra assailed the CA Decision, arguing that the prosecution failed to establish every link in the chain of custody of the dangerous drugs allegedly seized from them.
Issue(s)
Whether the Court of Appeals committed reversible error when it upheld Edwin's and Taladua's conviction of violation of Sections 5 and 11, Article II of R.A. No. 9165, and whether Mary Antonette Del Rosario y Tamondong, despite her prior conviction through a plea bargain, must benefit from the acquittal of her co-accused Edwin and Taladua. Whether the prosecution sufficiently established the chain of custody of the seized dangerous drugs.
Ruling
The Supreme Court granted the appeal, reversed the Decision of the Court of Appeals, and set aside the Order of the Regional Trial Court. Accused-appellants Edwin Cordova y Manalastas and Jayson Taladua y Barbarra were acquitted of the crimes of violation of Sections 5 and 11, Article II of Republic Act No. 9165 on the ground of reasonable doubt and were ordered released from detention. The Order of the RTC concerning Mary Antonette Del Rosario y Tamondong was also set aside, and she was acquitted on the ground of reasonable doubt.
Ratio Decidendi
On the conviction and benefit of acquittal for co-accused: The Court ruled that Mary Antonette Del Rosario y Tamondong, despite her prior conviction through a plea bargain, must benefit from the acquittal of her co-accused Edwin and Taladua. The Court cited Section 11(a), Rule 122 of the Rules of Court, which states that a favorable judgment of acquittal shall benefit co-accused who did not appeal or whose convictions became final. The Court noted that Del Rosario was simultaneously arrested with Edwin and Taladua, and the marking and inventory of the drugs allegedly seized from them were conducted under the same flawed procedure. Therefore, the acquittal of Edwin and Taladua on the basis of the non-observance of the chain of custody rule squarely applied to Del Rosario, as the evidence against them was inextricably linked. The Court cited Fuentes v. People, People v. Dy, and People v. Fulgado to support this principle. On the failure to establish the chain of custody: The Court held that the prosecution failed to establish the first link in the chain of custody, which involves the seizure, marking, and conduct of inventory of the seized dangerous drugs. The testimonies of the prosecution witnesses revealed that the insulating witnesses, namely Barangay Captain Leo Garra and media representative Christopher Yu, were not present at or near the place of arrest at the time of apprehension. They were only contacted and arrived at least 25 minutes after the arrest of Edwin and Taladua. This delay in the marking and inventory of the seized items, without any justifiable ground offered by the prosecution, constitutes an unjustifiable deviation from the chain of custody rule. The Court emphasized that the integrity and evidentiary value of the seized items were not properly preserved due to these lapses. The Court cited Nisperos v. People and People v. Bartolini to underscore the importance of immediate marking and the consequences of failure to do so without justification. The Court concluded that the lapses created reasonable doubt regarding the identity of the corpus delicti, thus warranting acquittal.
Main Doctrine
The failure to establish an unbroken chain of custody of the seized dangerous drugs, particularly the immediate marking and inventory of the items after confiscation in the presence of the required witnesses, creates reasonable doubt as to the integrity and evidentiary value of the corpus delicti, warranting acquittal. A favorable judgment of acquittal for co-accused who were simultaneously arrested and whose cases are inextricably linked benefits other co-accused, even if their convictions have become final.