The failure of police officers to conduct the inventory and taking of photographs of seized dangerous drugs at the place of seizure, or to provide a justifiable reason for conducting it elsewhere (such as at the nearest police station or office of the apprehending team), constitutes a significant breach in the chain of custody, warranting the acquittal of the accused.

The case arose from a buy-bust operation conducted on October 19, 2015, in Dumaguete City, where accused-appellant Chris John Custodio y Argote, also known as "Bolongkoy," was arrested for allegedly selling and possessing shabu. The operation was initiated based on information from a confidential informant.

• On October 19, 2015, PO3 Al Lester Avila received information from a confidential informant about "Bolongkoy" selling shabu in Barangay Cadawinonan, Dumaguete City.
• A buy-bust operation was planned, with PO3 Avila as poseur-buyer, SPO1 Calugcugan as back-up, and coordination with PDEA.
• At the Cadawinonan Housing Project, PO3 Avila and the informant met the accused-appellant. The accused-appellant asked if PO3 Avila was the buyer.
• PO3 Avila gave the accused-appellant three P100.00 bills (boodle money), which the accused-appellant tucked into his waistband.
• The accused-appellant retrieved one small plastic sachet from a black plastic container and handed it to PO3 Avila.
• PO3 Avila, suspecting the sachet contained shabu, immediately arrested the accused-appellant.
• Upon frisking, PO3 Avila found five more plastic sachets, two tin foils, two lighters, the boodle money, and three more P100.00 bills in the accused-appellant's possession.
• PO3 Avila marked the seized items with the accused-appellant's initials, the date, and a symbol to distinguish the sachet from the sale from those found during the search.
• The team proceeded to the Provincial Intelligence Branch/Special Operations Group (PIB/SOG) office where PO3 Avila conducted the inventory, signed by him, Kagawad Zerna, media practitioner Neil Rio, and DOJ Representative Benlot. The items were photographed there.
• SPO4 Germodo, the team leader, testified he decided to conduct the inventory and photograph at the PIB/SOG office for security reasons, but the decision text highlights the prosecution failed to give any, much less sufficient, justification for this.
• The DOJ Representative and Kagawad Zerna testified that the items were already prepared and laid on a table when they were called to witness the inventory at the PIB/SOG office.
• The seized items were turned over to PO3 Manaban at the crime laboratory, who then passed them to PCI Llena for qualitative examination.
• PCI Llena confirmed the specimens tested positive for methamphetamine hydrochloride.
• The accused-appellant denied the charges, claiming he was on his way to buy food when he was accosted by PO2 Hans Baguio, frisked (nothing found), and taken to the PIB/SOG office where items were laid on a table before him.

• The accused-appellant (petitioner in the Motion for Reconsideration) argued for acquittal, assailing the regularity of the buy-bust operation.
• The accused-appellant asserted that the chain of custody was breached.
• The accused-appellant contended that the subsequent presence of required witnesses during the inventory at the police station did not cure the irregularities because the integrity of the seized items had already been compromised at the inception when the insulating witnesses were not present at the site of arrest and were merely called when the inventory was done at the police station.

• The prosecution (plaintiff-appellee) initially argued that guilt was established to a moral certainty, the seized items and their evidentiary value were properly preserved, the chain of custody was duly observed, and the corpus delicti was positively identified.
• The prosecution, through the lower courts' and initial Supreme Court affirmations, implicitly maintained that the elements of the crimes were proven and that any deviations in the chain of custody procedure were not fatal or were justified.
• Specifically, the Court of Appeals noted that the absence of insulating witnesses during the actual filling out of the inventory form does not per se render items inadmissible, and conducting inventory at the office instead of the arrest site was not unreasonable, especially with markings protecting evidentiary value.

• Whether the Court should grant the accused-appellant's Motion for Reconsideration.
• Whether the chain of custody over the seized dangerous drugs was properly established by the prosecution, particularly concerning the requirement of conducting the inventory and photography at the place of seizure or providing justifiable grounds for deviation.
• Whether the integrity and evidentiary value of the corpus delicti were preserved.

• The Supreme Court granted the Motion for Reconsideration and reversed its Resolution dated November 11, 2021.
• The Court ruled that the prosecution failed to provide any, much less sufficient, justification for why the inventory and photography of the seized items were conducted at the PIB/SOG office instead of at the place of arrest, as generally required.
• This failure broke the first and most important link in the chain of custody early on, casting serious doubt on the identity and integrity of the corpus delicti.
• The Court emphasized that compliance with succeeding links in the chain of custody cannot cure an incipient breach that already compromised the identity and integrity of the seized items.
• Due to the procedural infirmities in the chain of custody, the integrity and evidentiary value of the seized items were not preserved, necessitating the accused-appellant's acquittal.

• Chain of Custody in Drug Cases — This refers to the duly recorded authorized movements and custody of seized drugs or controlled chemicals or plant sources of dangerous drugs or laboratory equipment of each stage, from the time of seizure/confiscation to receipt in the forensic laboratory to safekeeping to presentation in court for destruction. The Court applied this by scrutinizing the first link: seizure and marking, and inventory and photography. The failure to conduct the inventory and photography at the place of seizure without justifiable grounds was deemed a fatal breach.
• Corpus Delicti in Drug Cases — This refers to the dangerous drug itself. Its identity and integrity must be established beyond reasonable doubt. The Court held that the breach in the chain of custody cast serious doubt on the identity and integrity of the corpus delicti, as there was no assurance against switching, planting, or contamination.
• Warrantless Seizures (Inventory and Photography Requirements) — In cases of warrantless seizures, such as buy-bust operations, the inventory and taking of photographs generally must be conducted at the place of seizure. An exception exists if police officers provide justification that: (1) it is not practicable to conduct it at the place of seizure; or (2) the items seized are threatened by immediate or extreme danger. This justification must be sensible, practicable, consistent, not merely generic, and indicated in police affidavits. The Court found no such justification was provided in this case.
• Presumption of Innocence — While not explicitly detailed as a doctrine, the Court's action to overturn a conviction due to procedural lapses by law enforcement underscores the fundamental right of an accused to be presumed innocent until proven guilty beyond reasonable doubt, which includes adherence to procedural safeguards. The Court reiterated the need for vigilance in drug cases to prevent wrongful convictions.

• "In the recent case of People v. Casa, the Court settled that, in case of warrantless seizures, the inventory and taking of photographs generally must be conducted at the place of seizure. The exception to this rule-where the physical inventory and taking of photographs of the seized item may be conducted at the nearest police station or at the nearest office of the apprehending officer or team-is when the police officers provide justification that: (1) it is not practicable to conduct the same at the place of seizure; or (2) the items seized are threatened by immediate or extreme danger at the place of seizure."
• "As it was, the prosecution here failed to give any justification, much less, a sufficient one, on why the inventory had to be conducted at the PIB/SOG of the Negros Oriental Provincial Police Office instead of the place of arrest. Evidently, therefore, the first and most important link was already broken early on."
• "If the chain of custody procedure had not been complied with, or no justifiable reason exists for its non-compliance, as in this case, then it is the Court's duty to overturn the verdict of conviction."
• "Time and again, we have exhorted courts 'to be extra vigilant in trying drug cases, lest an innocent person is made to suffer the unusually severe penalties for drug offenses.'"

• People v. Casa (G.R. No. 254208, August 16, 2022) — Cited for establishing the rule that inventory and photography in warrantless seizures must generally be at the place of seizure, and detailing the exceptions and justification required for deviation. This was the primary basis for finding the chain of custody breached.
• People v. Ismael (806 Phil. 21, 35 (2017)) — Referenced for the principle that a significant break in the chain of custody (like the initial one here) cannot be cured by compliance with subsequent links, as there's no assurance against switching, planting, or contamination.
• People v. Macud (822 Phil. 1016, 1042 (2017)) — Quoted to emphasize that while dangerous drugs are pernicious, efforts to combat them cannot trample on constitutional rights, especially of marginalized individuals prone to abuse by state officers.
• People v. Año (828 Phil. 439, 452-453 (2018)) — Cited in a footnote regarding the Court's duty to overturn a conviction if chain of custody is not complied with or no justifiable reason exists for non-compliance.
• People v. Rangaig (G.R. No. 240447, April 28, 2021) — Quoted in a footnote exhorting courts to be extra vigilant in drug cases to prevent innocent persons from suffering severe penalties.

• Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002), Section 5 — This section penalizes the sale, trading, administration, dispensation, delivery, distribution, and transportation of dangerous drugs. The accused-appellant was initially convicted under this section.
• Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002), Section 11 — This section penalizes the possession of dangerous drugs. The accused-appellant was initially convicted under this section.
• Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002), Section 21 (as amended by RA 10640) — While not explicitly quoted in the resolution part, the discussion on inventory, photography, and presence of witnesses directly pertains to the procedural requirements outlined in this section for the custody and disposition of confiscated, seized, and/or surrendered dangerous drugs. The Court's ruling heavily relies on the operationalization of this section's requirements.