In People v. Castillo, the Supreme Court affirmed the conviction of Marissa Castillo for the sale and possession of illegal drugs, despite acknowledging procedural lapses by the arresting officers. The Court emphasized that strict compliance with Section 21 of Republic Act No. 9165, regarding the handling of seized drugs, is not always mandatory. What is crucial is the preservation of the integrity and evidentiary value of the seized items. This ruling clarifies that even if law enforcement fails to follow every step of the prescribed procedure, a conviction can stand if the evidence convincingly demonstrates the accused’s guilt and the chain of custody remains unbroken, reinforcing the importance of substance over form in drug-related prosecutions.

Buy-Bust Operation or Frame-Up? When Chain of Custody Determines Guilt

The case revolves around Marissa Castillo’s appeal against her conviction for violating Sections 5 and 11 of Republic Act No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002. The charges stemmed from a buy-bust operation conducted by Pasig City police officers, who claimed Castillo sold and possessed methylamphetamine hydrochloride, commonly known as shabu. Castillo denied the charges, alleging that she was framed by the police. The central legal question is whether the prosecution successfully proved Castillo’s guilt beyond reasonable doubt, considering the alleged failure of the police officers to strictly comply with the procedural requirements outlined in Section 21 of R.A. 9165.

Castillo argued that the arresting officers failed to adhere to the procedural requirements of Section 21(1), Article II of Republic Act No. 9165. Specifically, she pointed to the lack of photographs and an inventory of the seized evidence, as well as the absence of representatives from the media, the Department of Justice (DOJ), and any elected public official during the operation. She maintained that this non-compliance compromised the chain of custody of the seized illegal drugs, warranting her acquittal. However, the Court disagreed, referencing the case of People v. Robelo:

Indeed[,] the police officers’ alleged violations of Sections 21 and 86 of Republic Act No. 9165 were not raised before the trial court but were instead raised for the first time on appeal. In no instance did appellant least intimate at the trial court that there were lapses in the safekeeping of seized items that affected their integrity and evidentiary value. Objection to evidence cannot be raised for the first time on appeal; when a party desires the court to reject the evidence offered, he must so state in the form of objection. Without such objection, he cannot raise the question for the first time on appeal.

The Court acknowledged Castillo’s claim of non-compliance with Section 21. However, it emphasized that non-compliance does not automatically render the arrest illegal or the seized items inadmissible. The crucial factor is whether the integrity and evidentiary value of the seized items were preserved. The Implementing Rules and Regulations of Republic Act No. 9165 provide a crucial caveat:

SECTION 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:

(a)    The apprehending officer/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; Provided, that the physical inventory and photograph shall be conducted at the place where the search warrant is served; or at the nearest police station or at the nearest office of the apprehending officer/team, whichever is practicable, in case of warrantless seizures; Provided, further, that non-compliance with these requirements under justifiable grounds, as long as the integrity and the 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[.]

The **chain of custody** is a critical element in drug cases. It refers to the sequence of duly recorded authorized movements and custody of seized drugs, from the moment of seizure to its presentation in court. The purpose of the chain of custody is to ensure that the evidence presented in court is the same evidence seized from the accused and that it has not been tampered with or altered in any way. The Court, in People v. Del Rosario, reiterated the importance of this rule:

As a method of authenticating evidence, the chain of custody rule requires that the admission of an exhibit be preceded by evidence sufficient to support a finding that the matter in question is what the proponent claims it to be. It would include testimony about every link in the chain, from the moment the item was picked up to the time it is offered into evidence, in such a way that every person who touched the exhibit would describe how and from whom it was received, where it was and what happened to it while in the witness’ possession, the condition in which it was received and the condition in which it was delivered to the next link in the chain. These witnesses would then describe the precautions taken to ensure that there had been no change in the condition of the item and no opportunity for someone not in the chain to have possession of the same.

While the Court acknowledged the procedural lapses in Castillo’s case, it found that the chain of custody was unbroken. PO2 Santos testified that three heat-sealed plastic sachets containing shabu were seized from Castillo during the buy-bust operation. He immediately marked the seized drugs at the place of apprehension. The illegal drugs were then turned over to PSI Pascual, who requested a laboratory examination. The contents of the plastic sachets tested positive for methylamphetamine hydrochloride. PO2 Santos later identified the same marked specimens in court. This unbroken chain, coupled with the credible testimonies of the police officers, convinced the Court of Castillo’s guilt.

Castillo’s defense rested on a claim of innocence and an allegation that she was framed by the police. However, the Court generally disfavors defenses of denial in drug cases. Unless there is clear and convincing evidence that the police officers did not properly perform their duties or were prompted by ill-motive, the testimony of the officers who caught the accused red-handed is given more weight. The Court also gave little weight to the corroborating testimony of Castillo’s daughter, considering her familial relationship and potential bias. Therefore, the Supreme Court affirmed the Court of Appeals’ decision, upholding Castillo’s conviction.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution proved beyond reasonable doubt that Marissa Castillo was guilty of selling and possessing illegal drugs, despite alleged procedural lapses by the police officers in handling the seized evidence. The focus was on whether the integrity and evidentiary value of the seized drugs were preserved, even if the police did not strictly comply with Section 21 of R.A. 9165.
What is Section 21 of R.A. 9165?	Section 21 of Republic Act No. 9165 outlines the procedures for the custody and disposition of confiscated, seized, and/or surrendered dangerous drugs. It mandates that the apprehending team immediately inventory and photograph the seized items in the presence of the accused, a media representative, a DOJ representative, and an elected public official.
What is the chain of custody?	The chain of custody refers to the sequence of duly recorded authorized movements and custody of seized drugs from the time of seizure/confiscation to receipt in the forensic laboratory to safekeeping to presentation in court for destruction. It ensures the integrity of the evidence by documenting every person who handled the drugs and how they were handled.
Why is the chain of custody important in drug cases?	The chain of custody is crucial because it ensures that the evidence presented in court is the same evidence seized from the accused and that it has not been tampered with or altered in any way. This helps to prevent the substitution or alteration of evidence, which could lead to a wrongful conviction.
What happens if the police fail to comply with Section 21 of R.A. 9165?	Non-compliance with Section 21 does not automatically render the arrest illegal or the seized items inadmissible. The Supreme Court has held that what is essential is that the integrity and evidentiary value of the seized items are preserved. If the prosecution can demonstrate that the chain of custody was unbroken, despite the procedural lapses, the evidence may still be admissible.
What is the defense of denial?	The defense of denial is a common defense in drug cases where the accused denies the charges and claims that they were framed by the police. The Supreme Court has generally viewed this defense with disfavor, as it is easily concocted.
Why did the Court give less weight to the testimony of the appellant’s daughter?	The Court gave less weight to the testimony of the appellant’s daughter because of her familial relationship with the accused. The Court noted that corroborating testimony from relatives is given less probative value than that of disinterested witnesses, due to the potential for bias.
What is the significance of the police officers’ credibility in drug cases?	The credibility of the police officers who conducted the buy-bust operation is a crucial factor in drug cases. The Supreme Court has stated that the successful prosecution of drug cases is dependent, in large part, on the credibility of the police officers. Their testimonies are generally accorded full faith and credit, in view of the presumption of regularity in the performance of public duties.

People v. Castillo underscores the judiciary’s practical approach to drug cases, prioritizing the integrity of evidence and the establishment of guilt beyond a reasonable doubt over strict adherence to procedural formalities. This decision highlights the importance of meticulous documentation and handling of evidence by law enforcement, while also recognizing that minor deviations from prescribed procedures do not automatically invalidate a conviction if the chain of custody remains unbroken. This ruling provides a balanced perspective, ensuring justice is served while maintaining safeguards against potential abuse.

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 vs. Marissa Castillo y Alignay, G.R. No. 190180, November 27, 2013