The Supreme Court’s decision in People v. Sabdula underscores the critical importance of maintaining an unbroken chain of custody in drug-related cases. The Court acquitted Sonny Sabdula due to the prosecution’s failure to conclusively establish that the seized substance was the same one presented in court. This ruling reinforces the constitutional presumption of innocence and highlights the necessity for law enforcement to meticulously follow procedural safeguards when handling drug evidence, ensuring the protection of individual rights against potential abuses.

Flaws in Evidence: How a Buy-Bust Operation’s Lapses Led to Acquittal

The case of People of the Philippines v. Sonny Sabdula y Amanda originated from a buy-bust operation conducted by the Central Police District (CPD) in Quezon City. Acting on a tip, police officers targeted Sonny Sabdula, also known as “Moneb,” for allegedly selling illegal drugs. During the operation, PO2 Bernard Centeno, acting as the poseur-buyer, allegedly purchased 0.10 gram of shabu from Sabdula in exchange for P200.00. Sabdula was arrested, and the substance was sent to the crime laboratory for analysis, which confirmed it to be methylamphetamine hydrochloride, or shabu. At trial, the prosecution presented PO2 Centeno as their primary witness, while Sabdula testified in his defense, claiming he was abducted and framed by the police. Sabdula’s sister also testified that the police extorted money from them. The Regional Trial Court (RTC) convicted Sabdula, a decision affirmed by the Court of Appeals (CA). The case reached the Supreme Court, questioning whether the evidence presented was sufficient to prove Sabdula’s guilt beyond a reasonable doubt, particularly regarding the integrity of the seized drugs.

The Supreme Court began its analysis by reiterating the fundamental principle that an accused person is presumed innocent until proven guilty beyond a reasonable doubt. The burden of proof rests entirely on the prosecution, which must present sufficient evidence to overcome this presumption. In drug-related cases, a crucial element is establishing the corpus delicti, or the body of the crime, which includes proving the identity and integrity of the seized drugs. This is especially critical due to the nature of illegal drugs, which are easily susceptible to tampering, alteration, or substitution.

The Court emphasized the importance of the **chain of custody**—the documented sequence of individuals who handled the evidence from the moment of seizure to its presentation in court. The Court quoted People of the Philippines v. Joselito Beran y Zapanta @ “Jose,” stating:

The purpose of the requirement of proof of the chain of custody is to ensure that the integrity and evidentiary value of the seized drug are preserved, as thus dispel unnecessary doubts as to the identity of the evidence. To be admissible, the prosecution must establish by records or testimony the continuous whereabouts of the exhibit, from the time it came into the possession of the police officers, until it was tested in the laboratory to determine its composition, and all the way to the time it was offered in evidence.

A key aspect of establishing the chain of custody is the immediate **marking** of the seized drugs by the apprehending officer. Marking involves placing the officer’s initials and signature on the seized items to distinguish them from other similar items. The Supreme Court has consistently held that failure to immediately mark seized drugs casts reasonable doubt on the authenticity of the corpus delicti. “Marking after seizure is the starting point in the custodial link,” the Court noted, “hence, it is vital that the seized contraband be immediately marked because succeeding handlers of the specimens will use the markings as reference.”

In Sabdula’s case, the records lacked evidence that the police marked the seized plastic sachet immediately upon confiscation or at the police station. Neither PO2 Centeno’s testimony nor the stipulated testimonies of PO3 Chantengco and PO1 Fortea mentioned any marking of the seized item. This omission raised serious concerns about the identification of the seized shabu. While the forensic chemist’s report indicated markings on the sachet, the absence of specifics on how, when, and where this marking was done, and who witnessed it, further undermined the prosecution’s case. The court also cited previous cases like Lito Lopez v. People of the Philippines and People of the Philippines v. Merlita Palomares y Costuna, where acquittals were based on the police’s failure to properly mark seized drugs.

The Court also pointed to the failure of the buy-bust team to comply with Section 21, paragraph 1, Article II of R.A. No. 9165, which requires the apprehending team to physically inventory and photograph the seized drugs immediately after seizure and confiscation. This must be done in the presence of the accused, or their representative, and representatives from the media, the Department of Justice (DOJ), and an elected public official. The Implementing Rules and Regulations (IRR) of R.A. No. 9165 provide some flexibility, allowing these procedures to be conducted at the nearest police station or office in case of warrantless seizures, provided that the integrity and evidentiary value of the seized items are properly preserved. However, in Sabdula’s case, there was no evidence of any effort to comply with these requirements.

The prosecution did not offer any justification for the failure to follow the prescribed procedures. The Court emphasized that “the justifiable ground for non-compliance must be adequately explained; the Court cannot presume what these grounds are or that they even exist.” In light of these significant procedural lapses, the Supreme Court found that the presumption of regularity in the performance of official duties could not be upheld. The Court quoted People v. Cantalejo stating that the presumption of regularity cannot prevail over the constitutional right of the accused to be presumed innocent.

The Supreme Court concluded that the prosecution failed to establish Sabdula’s guilt beyond a reasonable doubt. The gaps in the chain of custody created reasonable doubt as to whether the shabu seized from Sabdula was the same shabu brought to the crime laboratory and presented in court as evidence. The Court reversed the CA decision and acquitted Sabdula, ordering his immediate release from detention.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution sufficiently proved the guilt of Sonny Sabdula beyond a reasonable doubt for the crime of selling illegal drugs, considering the integrity and chain of custody of the seized substance. The Supreme Court focused on whether the prosecution had properly established the chain of custody for the seized drugs.
What is the chain of custody, and why is it important?	The chain of custody refers to the documented sequence of individuals who handle evidence, from seizure to presentation in court. It is important to ensure the integrity and evidentiary value of the evidence, preventing tampering or substitution.
Why was the immediate marking of seized drugs emphasized in this case?	Immediate marking is crucial because it serves as the starting point in the custodial link, allowing succeeding handlers to identify the evidence. Without it, there is a risk of confusion or substitution, casting doubt on the authenticity of the seized drugs.
What are the requirements of Section 21 of R.A. 9165 regarding the handling of seized drugs?	Section 21 requires the apprehending team to immediately inventory and photograph the seized drugs in the presence of the accused, or their representative, and representatives from the media, the DOJ, and an elected public official. This ensures transparency and accountability in handling drug evidence.
What happens if the police fail to comply with the requirements of Section 21 of R.A. 9165?	Non-compliance may render the seizure and custody of the drugs void and invalid, unless the prosecution can provide justifiable grounds for the non-compliance and demonstrate that the integrity and evidentiary value of the seized items were properly preserved. The justifiable ground for non-compliance must be adequately explained.
What is the presumption of regularity, and how does it apply in drug cases?	The presumption of regularity assumes that public officials perform their duties regularly and lawfully. However, this presumption is disputable and cannot override the accused’s constitutional right to be presumed innocent. When the performance of duties is tainted with irregularities, the presumption is effectively destroyed.
What was the outcome of the case?	The Supreme Court reversed the CA decision and acquitted Sonny Sabdula, finding that the prosecution failed to prove his guilt beyond a reasonable doubt. The Court cited procedural lapses committed by the apprehending team, creating a reasonable doubt on whether the shabu seized from the appellant was the same shabu that was brought to the crime laboratory for chemical analysis and eventually offered in court as evidence.
What is the significance of this ruling?	This ruling reinforces the importance of following proper procedures in drug-related cases to protect the rights of the accused. It serves as a reminder to law enforcement to be mindful of the required procedures in the seizure, handling, and safekeeping of confiscated drugs.

The Sabdula case serves as a critical reminder that the pursuit of justice must never come at the expense of due process and the protection of individual rights. The meticulous adherence to established procedures, particularly in handling evidence, is not merely a technicality but a fundamental safeguard against potential abuses and wrongful convictions. The call to action is clear: law enforcement must prioritize the integrity of their operations and ensure full compliance with the legal framework governing drug-related cases.

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, APPELLEE, VS. SONNY SABDULA Y AMANDA, APPELLANT, G.R. No. 184758, April 21, 2014