In People v. Torres, the Supreme Court affirmed that the failure to strictly comply with the chain of custody requirements under Republic Act No. 9165, particularly Section 21, does not automatically invalidate drug-related convictions. The crucial factor is whether the integrity and evidentiary value of the seized drugs have been preserved. This ruling offers a practical understanding that technical procedural lapses can be excused if the prosecution adequately demonstrates that the seized drugs presented in court are the same ones confiscated from the accused, ensuring justice is not compromised by minor deviations from protocol.

When a Technicality Can’t Cloud Justice: The Case of Mylene Torres

Mylene Torres was convicted of selling shabu in violation of Section 5, Article II of Republic Act No. 9165. The prosecution presented evidence indicating that a buy-bust operation was conducted, during which Torres sold a plastic sachet containing white crystalline substance to a police officer acting as a poseur-buyer. However, Torres appealed her conviction, arguing that the police officers failed to comply with the mandatory procedure for handling dangerous drugs, specifically the physical inventory and photographing of the seized item as required by Section 21 of R.A. 9165. She contended that this lapse created reasonable doubt regarding whether the substance presented in court was the same one seized from her.

The Supreme Court tackled the issue of whether non-compliance with Section 21 of Republic Act No. 9165 is a fatal flaw in the prosecution’s case. The Court emphasized that while adherence to the chain of custody rule is ideal, its primary objective is to ensure the integrity and evidentiary value of the seized drugs. The chain of custody rule, as outlined in paragraph 1, Section 21, Article II of R.A. 9165, states:

SEC. 21. Custody and Disposition of Confiscated, Seized, and/or Surrendered Dangerous Drugs, Plant Sources of Dangerous Drugs, Controlled Precursors and Essential Chemicals, Instruments/Paraphernalia and/or Laboratory Equipment. – The PDEA shall take charge and have custody of all dangerous drugs, plant sources of dangerous drugs, controlled precursors and essential chemicals, as well as instruments/paraphernalia and/or laboratory equipment so confiscated, seized and/or surrendered, for proper disposition in the following manner:

(1) 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 Court acknowledged that the police officers did not strictly adhere to the requirement of making a physical inventory and taking photographs of the seized item. However, it also cited the Implementing Rules and Regulations of R.A. 9165, which provide:

x x x Provided, further, that non-compliance with these requirements under justifiable grounds, as long as the integrity and evidentiary value of the seized items are properly preserved by the apprehending officer/team, shall not render void and invalid such seizures of and custody over said items[.]

Building on this, the Court emphasized that the essential element is the preservation of the integrity and evidentiary value of the seized items. This is crucial for determining the guilt or innocence of the accused. The Court found that, in this case, the prosecution had successfully demonstrated an unbroken chain of custody, despite the procedural deviations. PO1 Rivera retained possession of the seized item from the moment of sale until he turned it over to the investigator at the police station. He placed his initials on the sachet, and the item was subsequently subjected to laboratory examination, which confirmed the presence of methylamphetamine hydrochloride. PO1 Rivera also positively identified the item in court as the same one he had confiscated from Torres.

The Court also addressed the appellant’s claim that the prosecution failed to prove her guilt beyond a reasonable doubt. It reiterated the elements necessary for a successful prosecution of offenses involving the illegal sale of dangerous drugs: (1) the identity of the buyer and seller, the object of the sale, and the consideration; and (2) the delivery of the thing sold and payment. The Court found that the prosecution had established these elements through the testimonies of PO1 Rivera and PO1 Male, who testified about the buy-bust operation and Torres’s delivery of the shabu in exchange for money.

Furthermore, the Court noted that Torres had only raised the issue of non-compliance with Section 21 on appeal. This delay was considered fatal to her case, as it prevented the prosecution from presenting evidence of any justifiable grounds for the non-compliance. It is a settled rule that objections to evidence must be raised during trial to allow the opposing party the opportunity to address them.

The Court weighed the defense of denial against the positive identification by PO1 Rivera. It found that Torres’s bare denial was insufficient to overcome the presumption that government officials perform their duties in a regular and proper manner. Torres also failed to provide evidence of any ill motive on the part of the police officers, which further undermined her defense. Therefore, positive testimony holds more weight than a simple denial.

Therefore, in cases involving violations of the Dangerous Drugs Act, law enforcement officers are presumed to have acted regularly, absent evidence to the contrary. This presumption reinforces the credibility of their testimonies and the integrity of the evidence they present, provided that the prosecution establishes a clear and consistent chain of custody, as was done in this case. Even if the procedural chain is broken, the court looks at the overall situation if they preserved the integrity and evidentiary value of the evidence. This has a far reaching impact in drug cases.

FAQs

What was the key issue in this case?	The key issue was whether the failure to strictly comply with Section 21 of Republic Act No. 9165, regarding the chain of custody of seized drugs, invalidates a conviction for illegal drug sale.
What is the chain of custody rule?	The chain of custody rule refers to the process of documenting and maintaining control over seized evidence, ensuring its integrity from seizure to presentation in court. This includes proper handling, storage, and identification of the evidence.
Does non-compliance with Section 21 automatically lead to acquittal?	No, the Supreme Court clarified that non-compliance does not automatically invalidate a conviction, provided the prosecution can demonstrate that the integrity and evidentiary value of the seized items were preserved.
What is the most important factor in drug cases?	The most important factor is the preservation of the integrity and evidentiary value of the seized drugs, which ensures that the substance presented in court is the same one confiscated from the accused.
Why did the Court consider the delay in raising the issue of non-compliance with Section 21?	The Court considered the delay significant because it prevented the prosecution from presenting evidence of any justifiable grounds for the non-compliance, which is a crucial aspect of the law.
What weight did the Court give to the police officers’ testimonies?	The Court gave credence to the police officers’ testimonies, presuming they performed their duties regularly, especially since the accused failed to show any ill motive on their part.
What happens if there are deviations from the required procedure?	If there are deviations from the required procedure, the prosecution must still demonstrate that the integrity and evidentiary value of the dangerous drug seized were properly preserved.
Why did the court give more weight to the testimony of the poseur buyer?	The court gave more weight to the testimony of the poseur buyer because, as a law enforcement officer, they are presumed to have acted regularly in the performance of their duties, absent evidence to the contrary.

In conclusion, the Supreme Court’s decision in People v. Torres underscores the importance of preserving the integrity and evidentiary value of seized drugs in drug-related cases. While strict compliance with procedural requirements is encouraged, it is not the sole determinant of guilt. The Court’s focus on ensuring the validity of evidence serves to balance the need for procedural rigor with the pursuit of justice.

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. Torres, G.R. No. 191730, June 05, 2013