In People v. Gonzales, the Supreme Court acquitted Alberto Gonzales y Vital of drug sale and possession charges, reversing the lower courts’ conviction. The Court found substantial inconsistencies in the testimonies of the prosecution witnesses regarding the buy-bust operation, particularly concerning who apprehended Gonzales and confiscated the evidence. This failure to present a coherent narrative and establish an unbroken chain of custody of the evidence raised reasonable doubt, leading to Gonzales’ acquittal. The decision underscores the importance of consistent and credible witness testimony in drug-related cases, emphasizing that the presumption of innocence must prevail when doubts exist.

Conflicting Accounts: Did a Buy-Bust Really Happen in Mabalacat?

Alberto Gonzales was accused of violating Sections 5 and 11 of R.A. No. 9165, the Dangerous Drugs Act of 2002, for allegedly selling and possessing shabu (methamphetamine hydrochloride). The prosecution’s case rested on the testimonies of PO3 Dindo Dizon and PO2 Romeo Yambao, who claimed that a buy-bust operation was conducted based on information received from a civilian informant. However, the Supreme Court found significant inconsistencies in their accounts of the events, casting doubt on the validity of the operation.

Central to the Court’s decision was the conflicting testimony regarding who apprehended Gonzales and seized the second sachet of shabu and marked money. PO3 Dizon initially testified that PO2 Yambao made the arrest and seizure, but later changed his statement, claiming that he himself apprehended Gonzales. PO2 Yambao, on the other hand, testified that it was PO3 Dizon who arrested Gonzales and confiscated the items. This discrepancy was considered a material inconsistency that undermined the prosecution’s case. The Court emphasized that the identities of the arresting officer and the seizing officer are crucial for establishing the chain of custody and the integrity of the evidence.

The Supreme Court highlighted the importance of consistent testimonies from prosecution witnesses, especially in drug cases, stating,

in some instances[,] law enforcers resort to the practice of planting evidence to extract information or even to harass civilians.

In light of this potential for abuse, the Court stressed the need for vigilance and adherence to established procedures to protect the rights of the accused. The presumption of regularity in the performance of official duties does not override the constitutional presumption of innocence.

Furthermore, the Court questioned PO3 Dizon’s claim that PO2 Yambao placed his initial, “RY,” on the second sachet of shabu. This was contradicted by the confiscation receipt prepared by PO3 Dizon himself, which indicated that the sachet was marked “DSD-2,” suggesting that PO3 Dizon was the one who confiscated it. This inconsistency further eroded the credibility of the prosecution’s witnesses. It is important to note that clear discrepancies in the narrative of the supposed buy-bust operation created reasonable doubt as to the veracity of the charges against Gonzales.

The prosecution’s account was further undermined by PO3 Dizon’s conflicting statements regarding the involvement of P/Insp. Efren David in the buy-bust operation. While PO3 Dizon initially claimed that P/Insp. David led the operation, his affidavit of arrest and subsequent testimony indicated that P/Insp. David did not participate. This inconsistency raised further questions about the accuracy and reliability of the prosecution’s version of events.

Considering these inconsistencies, the Supreme Court concluded that the testimonies of PO3 Dizon and PO2 Yambao could not be given credence. The Court explained the implications of conflicting testimonies, stating that,

where the testimonies of two key witnesses cannot stand together, the inevitable conclusion is that one or both must be telling a lie, and their story a mere concoction.

The Court acknowledged that Gonzales’ defense of denial was weak and uncorroborated. However, it emphasized that the weakness of the defense does not strengthen the prosecution’s case. The prosecution must prove the guilt of the accused beyond reasonable doubt, regardless of the strength or weakness of the defense. The Court reiterated that the evidence for the prosecution must stand or fall on its own weight and cannot be allowed to draw strength from the weakness of the defense.

The prosecution failed to establish an unbroken chain of custody of the seized drugs, which is a crucial element in drug cases. The chain of custody requires that the identity and integrity of the seized drugs be preserved from the moment of seizure until they are presented in court as evidence. This involves proper marking, handling, storage, and transportation of the drugs, as well as documentation of each step in the process.

Section 21 of R.A. No. 9165 outlines the procedure for handling seized drugs, which includes the immediate marking and inventory of the drugs at the place of seizure in the presence of the accused, a representative from the media, a representative from the Department of Justice (DOJ), and any elected public official. While the law allows for exceptions to this procedure under justifiable circumstances, the prosecution must provide a reasonable explanation for any deviations. In Gonzales’ case, the Court found that the prosecution failed to provide a sufficient explanation for the lapses in the chain of custody, further undermining the credibility of the evidence.

FAQs

What was the key issue in this case?	The central issue was whether the prosecution presented sufficient evidence to prove the guilt of Alberto Gonzales beyond reasonable doubt for the crimes of selling and possessing illegal drugs. The Court focused on inconsistencies in the testimonies of the prosecution witnesses.
Why did the Supreme Court acquit Alberto Gonzales?	The Supreme Court acquitted Gonzales due to significant inconsistencies in the testimonies of the prosecution witnesses, which raised reasonable doubt about the veracity of the buy-bust operation. The conflicting accounts of who made the arrest and seized the evidence were particularly problematic.
What is the importance of the chain of custody in drug cases?	The chain of custody is crucial in drug cases because it ensures the integrity and identity of the seized drugs from the moment of seizure until they are presented in court as evidence. It prevents tampering, substitution, or alteration of the evidence.
What did the Court say about the presumption of regularity in the performance of official duties?	The Court clarified that the presumption of regularity does not override the constitutional presumption of innocence. Law enforcement officers are still required to present credible and consistent evidence to prove the guilt of the accused beyond reasonable doubt.
What happens when the testimonies of key witnesses contradict each other?	When the testimonies of key witnesses contradict each other on material points, it casts doubt on the veracity of their accounts and undermines the credibility of the prosecution’s case. The Court may conclude that one or both witnesses are not telling the truth.
How does the weakness of the defense affect the prosecution’s case?	The weakness of the defense does not strengthen the prosecution’s case. The prosecution must prove the guilt of the accused beyond reasonable doubt, regardless of the strength or weakness of the defense’s evidence.
What is a “buy-bust” operation?	A buy-bust operation is a form of entrapment employed by law enforcement officers as an effective way of apprehending drug offenders. It typically involves a poseur-buyer who pretends to purchase illegal drugs from a suspect, leading to the suspect’s arrest.
What is the role of a poseur-buyer in a buy-bust operation?	In a buy-bust operation, a poseur-buyer pretends to purchase illegal drugs from a suspect. After the exchange, the poseur buyer gives a pre-arranged signal to the rest of the team, resulting to the arrest of the suspect.

The Supreme Court’s decision in People v. Gonzales serves as a reminder of the importance of credible and consistent evidence in drug cases. Law enforcement officers must adhere to established procedures and ensure that the integrity of the evidence is preserved. The presumption of innocence must be upheld, and any doubts about the guilt of the accused must be resolved in their favor. This ruling sets a clear precedent for future drug cases, emphasizing the need for vigilance and adherence to established procedures to protect the rights of the accused.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People of the Philippines, vs. Alberto Gonzales y Vital, G.R. No. 233544, March 25, 2019