In People v. Partoza, the Supreme Court acquitted Edwin Partoza of illegal drug charges, reversing his conviction due to the prosecution’s failure to adhere to mandatory procedures for handling seized drugs. The Court emphasized the importance of maintaining a clear chain of custody for evidence, reinforcing protections against potential evidence tampering and upholding the accused’s right to a fair trial. This ruling highlights the critical role of proper procedure in ensuring the integrity of drug-related prosecutions.

Busted Buy-Bust: When a Shabu Sale Leads to an Acquittal

This case revolves around the arrest and subsequent conviction of Edwin Partoza for the crimes of possession and sale of dangerous drugs, specifically shabu. The prosecution presented evidence of a buy-bust operation where Partoza allegedly sold shabu to an undercover police officer. Following his arrest, another sachet of shabu was found on his person. But the crucial legal question is: Did the police follow proper procedure in handling the seized drugs, and was the evidence presented against Partoza reliable enough to prove his guilt beyond a reasonable doubt?

The facts presented by the prosecution centered on the testimony of PO3 Juanito Tougan, who claimed to have acted as the poseur-buyer in a buy-bust operation. According to PO3 Tougan, he purchased shabu from Partoza and subsequently arrested him, recovering another sachet of the drug. However, the defense argued that the police did not follow proper procedures in handling the seized drugs, particularly concerning the chain of custody. Chain of custody refers to the documented and unbroken transfer of evidence from the time of seizure to its presentation in court, ensuring that the evidence is authentic and untainted.

Section 21(1) of Republic Act No. 9165 (R.A. No. 9165), otherwise known as the Comprehensive Dangerous Drugs Act of 2002, outlines the procedures for the custody and disposition of confiscated, seized, or surrendered drugs. Specifically, it states:

the apprehending team having initial custody and control of the drugs shall, immediately after seizure and confiscation, physically inventory and photograph the same in the presence of the accused or the person/s from whom such items were confiscated and/or seized, or his/her representative or counsel, a representative from the media and the Department of Justice (DOJ), and any elected public official who shall be required to sign the copies of the inventory and be given a copy thereof.

The Supreme Court found that the police failed to comply with these mandatory procedures. PO3 Tougan admitted that he only marked the seized drugs at the police station, not immediately after the arrest in the presence of Partoza. No inventory or photograph of the drugs was taken in the presence of the accused or any representatives from the media, the Department of Justice, or any elected public official. This non-compliance raised serious doubts about the integrity and identity of the evidence.

The Court also noted a gap in the chain of custody. While PO3 Tougan testified that he had possession of the drugs immediately after the arrest, the prosecution failed to provide evidence on how the seized items were handled from the time they left his hands until they were presented in court. The records lacked information on who had custody of the drugs after the laboratory examination and pending its presentation in court. This missing link in the chain of custody further undermined the prosecution’s case.

The prosecution relied heavily on the presumption of regularity in the performance of official duties. However, the Court clarified that this presumption only applies when there are no contrary details raising doubt about the regularity of the performance of official duties. In this case, the police’s failure to comply with the standard procedures prescribed by law negated the application of the presumption of regularity.

Due to the prosecution’s failure to establish the chain of custody and comply with the mandatory procedures under Section 21 of R.A. No. 9165, the Supreme Court reversed the decision of the lower courts and acquitted Edwin Partoza. The Court emphasized that the identity of the corpus delicti, which is the body of the crime or the actual substance of the crime, must be proven beyond reasonable doubt. In this case, the doubts surrounding the handling of the seized drugs were significant enough to warrant an acquittal.

This case illustrates the critical importance of adhering to proper procedures in drug-related cases. Law enforcement officers must follow the rules for handling seized drugs to ensure the integrity of the evidence and protect the rights of the accused. Failure to do so can result in the dismissal of charges, regardless of the perceived guilt of the accused.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution successfully established the chain of custody for the seized drugs, and if the police complied with the mandatory procedures for handling drug evidence under R.A. No. 9165.
What is “chain of custody” in legal terms?	Chain of custody refers to the documented and unbroken transfer of evidence from the time of seizure to its presentation in court. It is designed to ensure that the evidence is authentic and has not been tampered with.
What does R.A. No. 9165 say about handling seized drugs?	R.A. No. 9165 mandates that the apprehending team must immediately inventory and photograph the seized drugs in the presence of the accused, as well as representatives from the media, the Department of Justice, and an elected public official.
Why is the chain of custody so important in drug cases?	The chain of custody is crucial in drug cases because it helps ensure the integrity and reliability of the evidence presented against the accused. Without a proper chain of custody, doubts can arise about whether the drugs were tampered with or misidentified.
What happened in this case that led to the acquittal?	The police failed to follow the mandatory procedures for handling the seized drugs. They did not immediately mark the drugs in the presence of the accused, and there was a gap in the documented transfer of the drugs from the police to the laboratory.
What is the “presumption of regularity” and why didn’t it apply here?	The presumption of regularity assumes that law enforcement officers perform their duties properly. However, this presumption does not apply when there is evidence to suggest that the officers did not follow proper procedures, as was the case here.
What does “corpus delicti” mean?	Corpus delicti refers to the body of the crime or the actual substance of the crime. In drug cases, it refers to the actual illegal drugs seized from the accused.
What is the practical takeaway from this case for law enforcement?	Law enforcement officers must strictly adhere to the procedures outlined in R.A. No. 9165 for handling seized drugs. Failure to do so can lead to the dismissal of charges, even if there is evidence suggesting the accused is guilty.

This case serves as a reminder that strict compliance with legal procedures is essential to uphold justice and protect the rights of the accused. Law enforcement agencies must prioritize proper training and adherence to these procedures to ensure the integrity of drug-related prosecutions and maintain public trust in the justice system.

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: THE PEOPLE OF THE PHILIPPINES, APPELLEE, EDWIN PARTOZA Y EVORA, APPELLANT., G.R. No. 182418, May 08, 2009