In the case of People of the Philippines v. Maritess Cayas, the Supreme Court acquitted the accused due to the prosecution’s failure to establish an unbroken chain of custody for the seized drugs. This ruling underscores the critical importance of strictly adhering to the procedures outlined in Republic Act No. 9165, or the Comprehensive Dangerous Drugs Act of 2002. The court emphasized that any unexplained gaps in the chain of custody raise doubts about whether the evidence presented in court was the same evidence seized from the accused. This decision serves as a reminder that the presumption of innocence prevails over the presumption of regularity in law enforcement, especially when the integrity of evidence is compromised. Strict adherence to the chain of custody rule is essential to protect the rights of the accused and uphold the principles of justice.

Broken Links: When Doubt Derails a Drug Conviction

Maritess Cayas was charged with illegal sale and possession of dangerous drugs after a buy-bust operation conducted by police officers in Noveleta, Cavite. The prosecution presented testimonies from the arresting officers, object evidence including buy-bust money and confiscated drugs, and documentary evidence to support their case. Cayas, however, presented a different version of events, claiming she was framed by the police. The Regional Trial Court (RTC) convicted Cayas, but the Court of Appeals (CA) affirmed the decision with modifications. The Supreme Court (SC) then reviewed the case to determine whether Cayas’ guilt was proven beyond a reasonable doubt.

The Supreme Court began its analysis by emphasizing the constitutional presumption of innocence. The Court then highlighted critical gaps in the prosecution’s evidence, particularly concerning the chain of custody of the seized drugs. To secure a conviction for illegal drug offenses, the prosecution must establish the corpus delicti—the body of the crime—beyond reasonable doubt, with the confiscated illicit drug at its core. The chain of custody rule, as outlined in Section 21 of R.A. No. 9165, is designed to ensure that the identity and integrity of the drug are preserved from the moment of seizure to its presentation in court.

Section 21 of R.A. No. 9165 and its implementing rules require specific procedures for handling seized drugs:

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.

In this case, the arresting officers failed to comply with these mandatory procedures. They did not conduct a physical inventory or photograph the confiscated items immediately after seizure. Instead, they turned over the drugs to PO3 Genuino, who was not part of the buy-bust team, at the police station. This procedural lapse, evident in PO2 Ronquillo’s testimony, raised serious doubts about whether the drugs presented in court were the same ones seized from Cayas.

The Court acknowledged that non-compliance with the prescribed procedure is not always fatal to the prosecution’s case, citing a provision in the Implementing Rules and Regulations (IRR) of R.A. 9165. However, this exception applies only under specific conditions. The prosecution must (1) recognize the procedural lapses and explain justifiable grounds for them, and (2) establish that the integrity and evidentiary value of the seized evidence were preserved. This means the prosecution must prove with moral certainty that the drug presented in court is the same one confiscated from the accused.

The Supreme Court referred to the importance of the chain of custody, as explained in Malillin v. People:

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.

The Court identified several critical links that must be established, including seizure and marking of the drug, turnover to the investigating officer, turnover to the forensic chemist, and submission of the marked drug to the court. In Cayas’ case, the arresting officers failed to mark the plastic sachets immediately after arrest, and the prosecution offered no explanation for this failure. This immediate marking is crucial to ensure that the seized items can be readily identified in court, even after being transferred between different individuals.

The Supreme Court noted a glaring inconsistency between the testimonies of the arresting officers and the documentary evidence. The officers testified that PO3 Genuino placed markings of “MC” and “MC-P” on the sachets, but the Request for Laboratory Examination and Chemistry Report showed different markings: “MC-BB 08 Oct 2003,” “MC-P-1,” and “MC-P2.” Additionally, PO1 Padilla testified that he and his team delivered the confiscated items to the crime laboratory, but the Request for Laboratory Examination indicated that PO1 Goquila made the delivery.

These procedural lapses and unexplained discrepancies raised significant doubts about whether the items presented in court were the same ones taken from Cayas. The prosecution failed to meet the conditions set by Section 21 (a), Article II of the IRR of R.A. No. 9165, as they did not acknowledge or explain the procedural lapses, nor did they provide sufficient proof that the integrity and evidentiary value of the seized items were preserved.

The Court emphasized that the prosecution cannot rely solely on the presumption of regularity in the performance of official duties. The right to be presumed innocent outweighs this presumption, which is merely statutory and rebuttable. Without the presumption of regularity, the testimonies of the arresting officers must independently establish proof beyond a reasonable doubt that the corpus delicti exists.

While Cayas’ defense of frame-up was viewed with disfavor, the weakness of the defense does not strengthen the prosecution’s case. The prosecution’s evidence must stand on its own merits and establish guilt beyond a reasonable doubt. In this case, the Supreme Court found that the prosecution failed to do so, leading to Cayas’ acquittal.

FAQs

What was the key issue in this case?	The primary issue was whether the prosecution established an unbroken chain of custody for the seized drugs, ensuring their integrity and identity from seizure to presentation in court. The Supreme Court found significant gaps in the chain of custody, leading to reasonable doubt about the evidence.
What is the chain of custody rule?	The chain of custody rule requires that every link in the chain, from the moment the item is seized to the time it is offered into evidence, be accounted for to ensure the integrity and identity of the evidence. This includes documenting who had possession of the evidence, where it was stored, and what condition it was in at each stage.
Why is the chain of custody important in drug cases?	In drug cases, the chain of custody is crucial because illegal drugs are easily susceptible to tampering, alteration, or substitution. A broken chain of custody casts doubt on whether the substance tested and presented in court is the same one seized from the accused.
What are the mandatory procedures after seizing illegal drugs?	Section 21 of R.A. No. 9165 requires the apprehending team to immediately conduct a physical inventory and photograph the seized items in the presence of the accused, a representative from the media, the Department of Justice, and an elected public official. These individuals must sign copies of the inventory.
What happens if these procedures are not followed?	Non-compliance with these procedures is not always fatal, but the prosecution must acknowledge the lapses and provide justifiable grounds for them. They must also establish that the integrity and evidentiary value of the seized evidence were preserved despite the lapses.
What is the presumption of regularity?	The presumption of regularity assumes that law enforcement officers perform their duties properly. However, this presumption cannot override the constitutional right of the accused to be presumed innocent, which requires the prosecution to prove guilt beyond a reasonable doubt.
What was the main reason for the acquittal in this case?	The main reason for Cayas’ acquittal was the prosecution’s failure to establish a clear and unbroken chain of custody for the seized drugs. The procedural lapses and inconsistencies in the evidence raised reasonable doubt about whether the drugs presented in court were the same ones seized from her.
What is the significance of the markings on the seized drugs?	Markings on seized drugs help identify and distinguish them throughout the chain of custody. Discrepancies in the markings, as seen in this case, can cast doubt on the integrity of the evidence and weaken the prosecution’s case.

The People v. Cayas case reinforces the importance of adhering to the strict requirements of R.A. No. 9165 to maintain the integrity of evidence in drug-related cases. By emphasizing the need for an unbroken chain of custody and the primacy of the presumption of innocence, the Supreme Court underscores the safeguards in place to protect individual rights within the Philippine justice system. The case serves as a stern reminder to law enforcement of the necessity for meticulous procedure, documentation, and accountability in handling evidence, particularly in cases where individual liberties are at stake.

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. Maritess Cayas y Calitis @ “Tetet”, G.R. No. 206888, July 04, 2016