In People v. Goco, the Supreme Court acquitted Placido Goco due to the prosecution’s failure to establish an unbroken chain of custody for seized drug evidence. This ruling underscores the critical importance of meticulously documenting and preserving the integrity of drug evidence from the point of seizure to its presentation in court. The decision serves as a stern reminder to law enforcement of the stringent requirements under Republic Act No. 9165, emphasizing that lapses in procedure can lead to the acquittal of the accused, regardless of the initial arrest.

Broken Links: How a Faulty Drug Chain Led to an Acquittal

The case began with allegations that Placido Goco sold and possessed dangerous drugs, specifically shabu, in Catarman, Northern Samar. Following a buy-bust operation, Goco was charged with violating Sections 5 and 11 of Republic Act No. (RA) 9165, also known as the “Comprehensive Dangerous Drugs Act of 2002.” The prosecution presented testimonies from police officers involved in the operation, claiming that Goco sold shabu to a poseur-buyer and was found in possession of additional sachets during a subsequent search. However, the defense argued that the evidence was mishandled, thereby compromising its integrity.

At trial, the Regional Trial Court (RTC) convicted Goco, a decision later affirmed with modifications by the Court of Appeals (CA). Dissatisfied, Goco appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt. The central issue before the Supreme Court was whether the prosecution had adequately established the chain of custody of the seized drugs, a crucial element in drug-related cases under Philippine law.

The Supreme Court meticulously examined the requirements of Section 21, Article II of RA 9165, which outlines the procedure for handling seized drugs. This section mandates that the apprehending team, immediately after seizure, conduct a physical inventory and photograph the seized items in the presence of the accused, a representative from the media and the Department of Justice, and any elected public official. This process is designed to ensure transparency and prevent any tampering or substitution of evidence.

Section 21 (1), Article II of RA 9165 states that the apprehending team shall, immediately after seizure and confiscation, conduct a physical inventory and photograph the seized items in the presence of the accused or the person from whom the items were seized, his representative or counsel, a representative from the media and the Department of Justice, and any elected public official who shall be required to sign the copies of the inventory and be given a copy of the same.

The Court noted several critical lapses in the prosecution’s handling of the evidence. First, there was a lack of clarity regarding who marked the seized sachets of drugs, when they were marked, and how their custody was transferred after the seizure. The testimony of P02 Emano, the poseur-buyer, was vague on these crucial details. Further, the testimonies of SP03 Belga and SP04 Cabagsang provided conflicting accounts of their involvement in the buy-bust operation, casting doubt on the reliability of the police officers’ accounts.

Building on this principle, the Supreme Court highlighted that marking the drugs immediately upon seizure is essential as it serves as the starting point in the custodial link. It gives subsequent handlers a reference and separates the marked evidence from all other similar or related evidence, preventing switching, planting, or contamination of evidence. In this case, the prosecution’s failure to establish who handled the seized items after P02 Emano, how their custody was transferred, and when and how they were marked proved fatal to their case.

Also, crucial in proving the chain of custody is the marking of the seized drugs or other related items immediately after they are seized from the accused.

This approach contrasts with cases where minor deviations from the prescribed procedure are deemed excusable, provided that the integrity and evidentiary value of the seized items are properly preserved. However, in Goco’s case, the Court found that the cumulative effect of the procedural lapses raised serious doubts about the integrity and evidentiary value of the seized drugs.

The Supreme Court reiterated the importance of maintaining a clear and unbroken chain of custody, which means the duly recorded authorized movements and custody of seized drugs or controlled chemicals from the moment of seizure, to receipt by the forensic laboratory, to safekeeping, and finally to the presentation of the drugs in court for destruction. The fungible nature of shabu, which is similar in appearance to other substances, necessitates strict compliance with the chain of custody rule to prevent any possibility of substitution or tampering.

The Court emphasized that when the evidence sought to be presented is not distinctive and not readily identifiable, or when its condition at the time of testing or trial is critical, the chain of custody requirement must be strictly applied. This is because the exhibit’s level of susceptibility to alteration, tampering, contamination, and substitution dictates the level of strictness in applying the chain of custody rule. The prosecution’s failure to meet this standard resulted in reasonable doubt, leading to Goco’s acquittal.

Moreover, the Court underscored that the corpus delicti, which refers to the actual substance of the crime, must be proven with moral certainty. It must be shown that the drugs presented in court as evidence are the same items seized from the accused during the buy-bust operation. Since the prosecution failed to do so, Goco was acquitted on the ground of reasonable doubt.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution adequately established the chain of custody of the seized drugs, a crucial element in drug-related cases under Philippine law. The Supreme Court found significant lapses in the handling of the evidence.
What does the chain of custody rule require?	The chain of custody rule requires the prosecution to account for each link in the chain of possession of the seized drugs, from the moment of seizure to its presentation in court. This includes documenting who handled the drugs, how they were stored, and when they were transferred.
Why is the chain of custody important in drug cases?	The chain of custody is crucial to ensure that the drugs presented in court are the same ones seized from the accused, and that they have not been tampered with or substituted. This is especially important for substances like shabu, which are fungible and easily mistaken for other substances.
What happens if the chain of custody is broken?	If the chain of custody is broken, the integrity and evidentiary value of the seized drugs are compromised, and the accused may be acquitted due to reasonable doubt. The prosecution must prove an unbroken chain to secure a conviction.
What is the role of marking the seized drugs?	Marking the drugs immediately upon seizure is crucial as it provides a reference point for subsequent handlers and helps separate the evidence from other similar substances. It serves as a safeguard against switching, planting, or contamination of evidence.
What did the Supreme Court decide in this case?	The Supreme Court reversed the decision of the Court of Appeals and acquitted Placido Goco. The Court found that the prosecution failed to establish an unbroken chain of custody for the seized drugs, leading to reasonable doubt about their integrity.
What specific lapses did the police commit in this case?	The police failed to provide clear testimonies on who handled the seized items after the initial seizure, how their custody was transferred, and when and how they were marked. These inconsistencies raised doubts about the reliability of the police officers’ accounts.
What is the significance of Section 21 of RA 9165?	Section 21 of RA 9165 outlines the procedure that police officers must follow in handling seized drugs to preserve their integrity and evidentiary value. It mandates physical inventory and photography of the seized items in the presence of specific individuals.

The Supreme Court’s decision in People v. Goco serves as a landmark reminder of the stringent requirements for handling drug evidence under Philippine law. Law enforcement agencies must ensure strict compliance with the chain of custody rule to uphold the integrity of evidence and secure convictions in drug-related cases. Failures in this regard can result in the acquittal of the accused, regardless of other evidence presented.

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 v. Placido Goco y Ombrog, G.R. No. 219584, October 17, 2016