In People v. Manabat, the Supreme Court acquitted the accused due to the prosecution’s failure to establish an unbroken chain of custody for the seized drugs, underscoring the critical importance of adhering to procedural safeguards in drug-related offenses. This ruling emphasizes that even in buy-bust operations, strict compliance with legal procedures is essential to protect individual rights and ensure the integrity of evidence. This case serves as a reminder that the presumption of innocence prevails, and the prosecution bears the burden of proving guilt beyond a reasonable doubt by demonstrating an untainted chain of custody.

From Buy-Bust to Bust: When Procedural Lapses Lead to Acquittal

The case revolves around Mario Manabat’s arrest for allegedly selling and possessing methamphetamine hydrochloride (shabu) during a buy-bust operation. The prosecution presented testimonies from police officers who claimed to have apprehended Manabat after a confidential informant facilitated a drug transaction. Manabat, however, denied the charges, asserting that he was merely apprehended and framed by the police. The Regional Trial Court (RTC) found Manabat guilty, a decision affirmed by the Court of Appeals (CA). However, the Supreme Court took a different view, scrutinizing the procedural aspects of the arrest and evidence handling.

At the heart of the Supreme Court’s decision lies the issue of chain of custody, a legal principle vital in drug cases. This principle requires that the prosecution account for the continuous whereabouts of the seized drugs, from the moment of confiscation to their presentation in court as evidence. Section 21, Article II of Republic Act No. 9165 (RA 9165), also known as “The Comprehensive Dangerous Drugs Act of 2002,” outlines the procedures that law enforcement officers must follow to maintain the integrity of seized drugs. The Supreme Court emphasized that strict compliance with these procedures is not merely a formality but a crucial safeguard against potential abuse.

Section 21 of RA 9165 mandates that the seized items be inventoried and photographed immediately after seizure or confiscation. This inventory and photographing must occur in the presence of the accused or their representative or counsel, an elected public official, a representative from the media, and a representative from the Department of Justice (DOJ). All these individuals must sign the copies of the inventory and receive a copy themselves. The purpose of these requirements is to ensure transparency and accountability in the handling of evidence, minimizing the risk of tampering or planting of evidence.

The Supreme Court found several critical lapses in the handling of evidence in Manabat’s case. First, the witnesses required by Section 21 were not present at the time of the arrest. The police officers only contacted the witnesses after Manabat had already been apprehended and handcuffed. This delay violated the requirement that the inventory and photographing be conducted “immediately after seizure and confiscation.” As the court noted, buy-bust operations are planned activities, and there is typically ample time to secure the presence of the required witnesses beforehand.

The presence of the witnesses from the DO J, media, and from public elective office is necessary to protect against the possibility of planting, contamination, or loss of the seized drug. Using the language of the Court in People v. Mendoza, without the insulating presence of the representative from the media or the DOJ and any elected public official during the seizure and marking of the drugs, the evils of switching, “planting” or contamination of the evidence that had tainted the buy-busts conducted under the regime of RA No. 6425 (Dangerous Drugs Act of 1972) again reared their ugly heads as to negate the integrity and credibility of the seizure and confiscation of the subject sachet that was evidence of the corpus delicti, and thus adversely affected the trustworthiness of the incrimination of the accused.

Second, the Certificate of Inventory was not signed by Manabat or his counsel, and the prosecution failed to provide any explanation for this omission. While Section 21 of the Implementing Rules and Regulations (IRR) of RA 9165 allows for noncompliance under justifiable grounds, the prosecution must first acknowledge the lapse and then justify it. In Manabat’s case, the prosecution did neither, further undermining the integrity of the evidence. Even if justifiable grounds exist, the prosecution’s silence on the matter cast doubt on the veracity and reliability of the inventory process.

Third, the marking of the plastic sachets allegedly recovered from Manabat was irregularly done. According to the Philippine National Police Drug Enforcement Manual, the seizing officer and the evidence custodian must mark the evidence with their initials and indicate the date, time, and place of confiscation. In Manabat’s case, only the date and initials of the seizing officers were inscribed on the specimens, with no indication of the time and place of the buy-bust operation. This failure to adhere to established procedures further compromised the chain of custody.

The Supreme Court emphasized that the prosecution bears the burden of proving compliance with the procedure outlined in Section 21. This burden never shifts to the accused, who is presumed innocent until proven guilty beyond a reasonable doubt. The prosecution’s failure to provide justifiable grounds for the apprehending team’s deviation from the rules laid down in Section 21 compromised the integrity and evidentiary value of the corpus delicti, leading to Manabat’s acquittal. The Court further clarified that the presumption of regularity in the performance of duties cannot overcome the stronger presumption of innocence in favor of the accused. This principle prevents a mere rule of evidence from undermining a constitutionally enshrined right.

The Court highlighted that relying on the presumption of regularity was erroneous, especially given the numerous indicia of serious lapses by the police officers. The presumption of regularity cannot be plucked out from thin air but must be inferred from established basic facts. In Manabat’s case, the irregularities committed by the police officers precluded any presumption of regularity in their favor. The court therefore provided for this comparation:

Presumption of Regularity	Presumption of Innocence
An evidentiary tool to streamline government operations.	A fundamental right protecting the accused.
Applies when there is no evidence of irregularity.	Applies until guilt is proven beyond reasonable doubt.
Cannot override constitutional rights.	Takes precedence over evidentiary presumptions when there is doubt.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution had established an unbroken chain of custody for the seized drugs, as required by Section 21 of RA 9165.
What is the “chain of custody” in drug cases?	Chain of custody refers to the sequence of transfers of evidence, documenting who handled the evidence and when, to ensure the integrity and identity of the evidence.
Why is the chain of custody important in drug cases?	It is important to ensure that the substance offered in court is the same as that recovered from the suspect, without any possibility of alteration or substitution.
What does Section 21 of RA 9165 require?	It mandates that the seized items be inventoried and photographed immediately after seizure in the presence of the accused, an elected official, and representatives from the media and the DOJ.
What happens if there are lapses in the chain of custody?	If the prosecution fails to justify such lapses, the integrity and evidentiary value of the corpus delicti are compromised, potentially leading to an acquittal.
Can the presumption of regularity overcome reasonable doubt?	No, the presumption of regularity in the performance of official duties cannot override the stronger presumption of innocence in favor of the accused.
What was the outcome of this case?	The Supreme Court acquitted Mario Manabat due to the prosecution’s failure to prove his guilt beyond a reasonable doubt, citing irregularities in the handling of evidence.
What is the significance of having witnesses present during the seizure?	The presence of witnesses helps to ensure transparency and prevent the planting, contamination, or loss of the seized drugs, which is important for a fair trial.

People v. Manabat serves as a critical reminder of the importance of adhering to procedural safeguards in drug cases. The Supreme Court’s decision underscores that strict compliance with Section 21 of RA 9165 is essential to protect individual rights and ensure the integrity of evidence. Any unexplained deviation from these procedures can compromise the chain of custody and lead to an acquittal, even in cases involving buy-bust operations.

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 v. Manabat, G.R. No. 242947, July 17, 2019