The Supreme Court held that the prosecution failed to establish an unbroken chain of custody for seized drugs, leading to the acquittal of the accused. This ruling underscores the critical importance of meticulously documenting and preserving drug evidence from the moment of seizure to its presentation in court. The decision reinforces that failure to strictly adhere to chain of custody requirements can undermine the integrity of evidence, creating reasonable doubt and preventing conviction.

Did the Police Compromise Drug Evidence? A Broken Chain Leads to Acquittal

In the case of People of the Philippines vs. Steve Siaton y Bate, the accused-appellant was charged with violating Section 5, Article II of R.A. No. 9165, also known as The Comprehensive Dangerous Drugs Act of 2002. The lower courts convicted Siaton based on a buy-bust operation conducted by the police. However, the Supreme Court reversed the decision, focusing on whether the integrity and evidentiary value of the seized substance had been preserved through an unbroken chain of custody. This case highlights the stringent requirements for handling drug evidence and the consequences of failing to meet them.

At the heart of the matter is the concept of corpus delicti, which in drug cases, refers to the actual dangerous drug itself. The Supreme Court emphasized that to secure a conviction, the prosecution must prove beyond reasonable doubt that the substance presented in court is the same one seized from the accused. This is where the chain of custody comes into play. The chain of custody is defined as the duly recorded authorized movements and custody of seized drugs at each stage, from seizure to presentation in court. This record includes the identity and signature of each person who held temporary custody of the seized item, the dates and times of transfers, and the final disposition of the evidence. The purpose of this chain is to ensure the integrity of the evidence and prevent tampering or substitution.

The elements of illegal sale of dangerous drugs require proof of the identity of the buyer and seller, the object, and the consideration, along with delivery of the thing sold and payment. The dangerous drug itself constitutes the corpus delicti, and its integrity must be preserved. This is because illegal drugs are indistinct, easily altered, and susceptible to tampering. Thus, establishing the chain of custody is critical to proving that the substance presented in court is the same one seized from the accused.

The Court referenced the case of Mallillin v. People to illustrate the chain of custody rule. The Court explained that the admission of an exhibit must be preceded by evidence sufficient to support a finding that the matter in question is what the proponent claims it to be. Ideally, the prosecution should present testimony about every link in the chain, from the moment the item was picked up to the time it was offered into evidence. Each person who touched the exhibit should describe how and from whom it was received, where it was, what happened to it while in their possession, and the conditions in which it was received and delivered.

The Supreme Court outlined four critical links in the chain of custody that must be established: First, the seizure and marking, if practicable, of the illegal drug recovered from the accused by the apprehending officer. Second, the turnover of the illegal drug seized by the apprehending officer to the investigating officer. Third, the turnover by the investigating officer of the illegal drug to the forensic chemist for laboratory examination. Fourth, the turnover and submission of the marked illegal drug seized by the forensic chemist to the court.

In this case, the Supreme Court found several glaring gaps in the chain of custody, particularly in the first, third, and fourth links. Regarding the first link, Section 21, paragraph 1, Article II of R.A. No. 9165 requires the apprehending team to physically inventory and photograph the seized drugs immediately after seizure, in the presence of the accused, a representative from the media, a representative from the Department of Justice (DOJ), and an elected public official. This procedure was not followed in Siaton’s case. The prosecution failed to provide evidence that a physical inventory and photograph of the seized items were taken in the presence of the accused or the required representatives.

The prosecution argued that non-compliance with these requirements should not render the seizure void if there were justifiable grounds and the integrity of the evidence was preserved. However, the Court noted that the prosecution failed to show any justifiable grounds for deviating from the required procedure. PO1 Ranile’s testimony, as well as that of PO1 Cuyos, was vague and failed to elaborate on the procedure undertaken. The absence of a clear record of when and where the marking of the seized substance was done further weakened the prosecution’s case.

Concerning the third link, Section 21, paragraphs 2 and 3, Article II of R.A. 9165 requires that the seized drugs be submitted to the PDEA Forensic Laboratory for examination within twenty-four hours of confiscation, and a certification of the forensic laboratory examination results should be issued within twenty-four hours after receipt of the item. The testimonies of PO1 Ranile and PO1 Cuyos provided minimal details about the turnover to the laboratory. The Request for Laboratory Examination showed that PO1 Abesia received the request and specimen, but the prosecution failed to demonstrate how the specimen was handled under PO1 Abesia’s custody and subsequently turned over to the forensic chemist, Jude Daniel M. Mendoza. The failure of Jude Mendoza to testify, despite being subpoenaed, further cast doubt on the integrity of this link.

Notably, during the pre-trial conference, the prosecution admitted that the chemistry report was not subscribed, containing only the qualitative examination results. The credibility and accuracy of the chemistry report hinged on the signature of the medical technologist. Without it, the possibilities for falsification or fabrication of the report were significantly increased. The trial court’s subsequent order to strike out this stipulation, months after the pre-trial conference, was deemed irregular by the Supreme Court. Stipulations made during pre-trial are binding, and absent a showing of manifest injustice, the trial court should not have allowed the prosecutor to withdraw the admission.

For the fourth link, the prosecution claimed that Prosecutor Geromo obtained the specimen from the laboratory and presented it to the court. However, the forensic chemist’s failure to testify meant there was no way to ascertain how the drugs were kept while in his custody. This left a significant gap in the chain, as there was no evidence showing precautions were taken to prevent changes in the condition of the specimen or unauthorized access. The Court concluded that the integrity of the corpus delicti was not preserved.

The Court emphasized that while the presumption of regularity in the performance of official duty may apply to police officers, it does so only when there is no deviation from the standard conduct of official duty required by law. In this case, the evidentiary gaps in the chain of custody undermined this presumption. When challenged by evidence of a flawed chain of custody, the presumption of regularity cannot prevail over the presumption of innocence of the accused. As a result, the Supreme Court resolved the doubt in favor of Siaton, leading to his acquittal.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution sufficiently established an unbroken chain of custody for the seized drugs, thereby preserving the integrity and evidentiary value of the corpus delicti.
What is the chain of custody in drug cases?	The chain of custody refers to the documented sequence of individuals who handled the seized drugs, from the moment of seizure to its presentation in court, ensuring that the evidence remains untainted and reliable.
Why is the chain of custody important in drug cases?	It’s crucial because it ensures the drug presented in court is the same one seized from the accused, preventing tampering or substitution, which is vital given the easily altered nature of drug evidence.
What are the required steps for the seizure and custody of drugs?	The steps include immediate marking of the seized drugs, physical inventory and photographing in the presence of the accused and required representatives, proper turnover to the investigating officer, and timely submission to the forensic laboratory.
What happens if the chain of custody is broken?	If the chain of custody is compromised, the integrity of the evidence is cast in doubt, potentially leading to the acquittal of the accused because the prosecution cannot prove the drug presented in court is the same one seized.
What are the roles of the apprehending officer and forensic chemist in maintaining the chain?	The apprehending officer must properly seize, mark, and turnover the drugs, while the forensic chemist must analyze and preserve the evidence, providing testimony on its handling and integrity.
What did the Supreme Court rule about the presumption of regularity in this case?	The Supreme Court ruled that the presumption of regularity in the performance of official duty does not apply when there are clear deviations from the established procedures for handling drug evidence.
How does this ruling impact future drug cases in the Philippines?	This ruling reinforces the importance of strict compliance with chain of custody requirements, serving as a reminder to law enforcement to meticulously document every step in handling drug evidence to ensure successful prosecution.

This Supreme Court decision serves as a stern reminder of the critical importance of adhering to the strict requirements of the chain of custody in drug-related cases. The gaps in evidence handling led to the acquittal of the accused. It emphasizes that strict compliance with procedural safeguards is not merely a technicality, but a fundamental requirement to protect the rights of the accused and ensure the integrity of the judicial process.

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. Steve Siaton Y Bate, G.R. No. 208353, July 04, 2016