In Luis Derilo y Gepoleo v. People of the Philippines, the Supreme Court acquitted the accused due to the prosecution’s failure to establish an unbroken chain of custody for the seized drugs. This means the prosecution did not convincingly prove that the drugs presented in court were the same ones confiscated from the accused, leading to reasonable doubt. This ruling underscores the critical importance of meticulously documenting and preserving evidence in drug-related cases to ensure the protection of individual rights and the integrity of the justice system.

Broken Links: How a Faulty Chain of Custody Led to an Acquittal

The case began with a search warrant served at Luis Derilo’s residence, where police officers, accompanied by barangay tanods, discovered twelve plastic sachets containing white crystalline substance and drug paraphernalia. Derilo was subsequently charged with violating Sections 11 and 12 of Republic Act No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002. The Regional Trial Court (RTC) found him guilty, a decision later affirmed by the Court of Appeals (CA). However, the Supreme Court reversed these decisions, focusing on significant gaps in the chain of custody of the seized items.

At the heart of the Supreme Court’s decision is the concept of chain of custody, which is essential in drug-related prosecutions. The Court emphasized that the dangerous drug itself constitutes the corpus delicti of the offense. To secure a conviction, the prosecution must prove beyond a reasonable doubt that the drug presented in court is the same one seized from the accused. The Court cited People v. Pedronan, stating:

For prosecutions involving dangerous drugs, the dangerous drug itself constitutes the corpus delicti of the offense and the fact of its existence is vital to sustain a judgment of conviction beyond reasonable doubt.

To ensure the integrity of the evidence, Section 21 of RA No. 9165 outlines specific procedures for handling seized drugs. The chain of custody rule demands a clear and documented trail from the moment of seizure to its presentation in court. This includes detailing who handled the evidence, how it was handled, where it was stored, and its condition at each stage. Any break in this chain can cast doubt on the authenticity and integrity of the evidence, potentially leading to an acquittal. The Court emphasized this point, quoting People v. Alivio:

To show an unbroken link in the chain of custody, the prosecution’s evidence must include testimony about every link in the chain, from the moment the item was seized to the time it is offered in court as evidence, such that every person who handled the evidence would acknowledge 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.

In Derilo’s case, the Supreme Court identified several critical flaws in the prosecution’s handling of evidence. The Court found a lack of evidence demonstrating that the plastic sachets containing the alleged shabu were marked by SPO1 Evasco, the apprehending officer, at the scene or even at the police station in the presence of the petitioner. The marking of seized drugs is a crucial first step in preserving their integrity, serving as a reference point for subsequent handlers. The Court, citing People v. Gonzales, stated that the marking immediately upon confiscation or recovery of the dangerous drugs or related items is indispensable in the preservation of their integrity and evidentiary value.

Further complicating matters, the Court noted inconsistencies between the initial Certification of Laboratory Examination and the subsequent Chemistry Report. These discrepancies pertained to the markings on the plastic sachets and the weight of the drug specimens. Such inconsistencies raised doubts about whether the specimens examined were indeed the same ones seized from Derilo. The Court pointed out the differences in the markings and weight, highlighting the unreliability of the evidence.

The Court also found significant gaps in the testimonies regarding the handling of the seized items. While SPO1 Calupit, PO2 Lobrin, and an unnamed receiving officer were identified as key individuals in the chain of custody, the prosecution failed to elicit detailed testimony from them about their handling of the evidence. This lack of clarity left the Court unconvinced that the specimens examined were the same ones confiscated from the petitioner. The Court found that the prosecution’s evidence was seriously lacking in details as to the links in the chain of custody of the seized items from the time they were confiscated up to the time they were presented in court.

Considering these deficiencies, the Supreme Court concluded that the prosecution failed to prove the corpus delicti of the offense beyond a reasonable doubt. Consequently, Derilo was acquitted of both charges: possession of dangerous drugs (Section 11) and possession of drug paraphernalia (Section 12) under RA No. 9165. As for the charge of possession of drug paraphernalia, the Court noted that the prosecution failed to prove that the items seized, such as aluminum foil and lighters, were intended for drug use. The Court emphasized that without such proof, a conviction under Section 12 of RA No. 9165 could not stand.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution successfully established an unbroken chain of custody for the seized drugs, proving that the drugs presented in court were the same ones confiscated from the accused.
What is the chain of custody in drug cases?	The chain of custody refers to the documented and unbroken trail of evidence, showing who handled it, how it was handled, where it was stored, and its condition at each stage, from seizure to presentation in court.
Why is the chain of custody important?	It ensures the integrity and authenticity of the evidence, preventing contamination, substitution, or alteration, and guarantees that the evidence used against the accused is the same as that seized.
What were the major flaws in the chain of custody in this case?	The flaws included the failure to mark the plastic sachets immediately upon seizure, inconsistencies in the markings and weight of the drug specimens, and a lack of detailed testimony about the handling of the evidence by key individuals.
What is the significance of marking seized drugs?	Marking the drugs immediately upon seizure is crucial for identifying them and ensuring that the drugs presented in court are the same ones confiscated from the accused.
What is corpus delicti in drug cases?	In drug cases, the corpus delicti is the actual dangerous drug itself, and the prosecution must prove its existence and identity beyond a reasonable doubt to secure a conviction.
What was the outcome of the case?	The Supreme Court acquitted Luis Derilo of both charges—possession of dangerous drugs and possession of drug paraphernalia—due to the prosecution’s failure to prove his guilt beyond a reasonable doubt.
What are the elements of illegal possession of drug paraphernalia?	The elements are: (1) possession or control of equipment intended for drug use; and (2) such possession is not authorized by law. The prosecution must prove the items were intended to be used as drug paraphernalia.

The Derilo case serves as a potent reminder of the meticulous standards required in drug-related prosecutions. The prosecution must present an unwavering case that accounts for every link in the chain of custody of the seized drugs. A failure to do so, as demonstrated in this case, can lead to the acquittal of the accused, regardless of other presented evidence. This ruling underscores the importance of adhering to proper procedures in handling evidence to protect individual rights and maintain the integrity of 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: Luis Derilo y Gepoleo v. People, G.R. No. 190466, April 18, 2016