In People v. Ameril, 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 meticulously following procedures for handling evidence in drug cases. The Court emphasized that inconsistencies in marking the evidence, coupled with a failure to properly document the handling of the drugs, created reasonable doubt as to whether the substance presented in court was the same one seized from the accused. This decision highlights that law enforcement must adhere strictly to chain of custody rules to ensure the integrity of evidence and protect the rights of the accused.

Broken Links: When Doubt Derails Drug Convictions

The case of People v. Mardan Ameril revolved around an alleged buy-bust operation where Ameril was accused of selling shabu. The prosecution presented evidence claiming that Ameril sold three packs of shabu to a confidential informant acting as a poseur-buyer. However, critical inconsistencies and procedural lapses in handling the evidence led the Supreme Court to question the integrity of the corpus delicti—the body of the crime, in this case, the seized drugs. This raised a fundamental legal question: Can a conviction for illegal drug sale stand when the chain of custody of the seized drugs is compromised, creating doubt about the evidence’s authenticity?

At the heart of this case is the concept of **chain of custody**, which the Court defined as “the 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” citing Dangerous Drugs Board Regulation No. 1, Series of 2002. Crucially, this includes documenting each stage of handling, identifying who held temporary custody, and recording the dates and times of transfer. The purpose of this rigorous process is to guarantee that the substance tested and presented in court is, without a doubt, the same substance seized from the accused.

The Supreme Court found significant flaws in how the prosecution handled the evidence. The most glaring was the conflicting testimony regarding who marked the seized sachets of shabu. One officer testified that the investigator made the markings, while another claimed he did it himself. This discrepancy, the Court noted, undermined the very foundation of the evidence’s integrity. As the Court emphasized, “Marking after seizure is the starting point in the custodial link and is vital to be immediately undertaken because succeeding handlers of the specimens will use the markings as reference,” citing People v. Nuarin, G.R. No. 188698, July 22, 2015.

Moreover, the prosecution failed to provide details about when and where the marking occurred, or whether it was done in the presence of the accused. This failure to adhere to proper procedure raised serious questions about the reliability of the evidence. In People vs. Sanchez, the Court previously stated that the marking of the seized items should be done immediately upon confiscation to ensure that they are the same items that enter the chain and are eventually offered in evidence.

Section 21(1) of R.A. No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002, mandates specific procedures for handling seized drugs. It requires that the apprehending team “immediately after seizure and confiscation, physically inventory and photograph the same in the presence of the accused… a representative from the media and the Department of Justice (DOJ), and any elected public official.” This provision aims to ensure transparency and accountability in drug-related operations.

In Ameril’s case, the prosecution presented no evidence of compliance with these requirements. There were no documents showing a physical inventory, no photographs of the seized drugs, and no explanation for the failure to follow the law. The Court has consistently held that strict compliance with Section 21 is crucial, and deviations must be justified to preserve the integrity of the evidence. The absence of this justification was a critical factor in the Court’s decision to acquit Ameril.

The Court also addressed the presumption of regularity in the performance of official duty, often invoked by law enforcement. While this presumption exists, it is not absolute and can be overturned by evidence of irregularities. In People v. Coreche, the Supreme Court ruled that the failure of authorities to immediately mark the seized drugs raises reasonable doubt on the authenticity of the corpus delicti and suffices to rebut the presumption of regularity in the performance of official duties. In this case, the inconsistencies in the marking process and the lack of compliance with Section 21 were sufficient to rebut the presumption and cast doubt on the police officers’ actions.

Furthermore, the Court emphasized that the presumption of regularity cannot override the constitutional presumption of innocence. Every accused person is presumed innocent until proven guilty beyond reasonable doubt. When there are doubts and irregularities in the handling of evidence, as in Ameril’s case, the presumption of innocence must prevail. The Court noted, “More importantly, the presumption of regularity in the performance of official duties is inferior to and cannot defeat the constitutional presumption of innocence”, citing People v. Cañete, G.R. No. 138400, July 11, 2002.

The decision in People v. Ameril serves as a stark reminder of the importance of meticulous adherence to procedural safeguards in drug cases. The integrity of the chain of custody is not a mere technicality but a fundamental requirement to ensure a fair trial and protect the rights of the accused. Failure to comply with these safeguards can lead to the suppression of evidence and, as in this case, the acquittal of the accused. This case highlights the critical role that proper evidence handling plays in upholding justice and preventing wrongful convictions.

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, ensuring the integrity and identity of the evidence presented in court. The Supreme Court found critical inconsistencies and procedural lapses that cast doubt on the evidence.
What is chain of custody?	Chain of custody refers to the documented process of tracking seized drugs from the moment of confiscation to their presentation in court. This includes recording who handled the evidence, when it was transferred, and how it was stored to prevent contamination or tampering.
Why is chain of custody important in drug cases?	It is vital to guarantee that the substance tested and presented in court is, without a doubt, the same substance seized from the accused. It ensures the integrity and reliability of the evidence, protecting the accused from wrongful convictions.
What is the significance of marking the seized drugs?	Marking the seized drugs immediately after confiscation is a crucial step in establishing chain of custody. It creates a reference point for all subsequent handlers of the evidence and helps prevent switching, planting, or contamination of evidence.
What does Section 21 of R.A. 9165 require?	Section 21 requires the apprehending team to immediately inventory and photograph the seized drugs in the presence of the accused, a media representative, a DOJ representative, and an elected public official. This promotes transparency and accountability in drug operations.
What is the presumption of regularity?	The presumption of regularity assumes that law enforcement officers perform their duties properly. However, this presumption can be rebutted by evidence of irregularities or deviations from established procedures, as demonstrated in this case.
How did the Court apply the presumption of innocence in this case?	The Court emphasized that the presumption of innocence is a fundamental right that outweighs the presumption of regularity. When there are doubts about the integrity of the evidence, the accused is entitled to the benefit of the doubt and must be acquitted.
What was the outcome of the case?	The Supreme Court reversed the lower courts’ decisions and acquitted Mardan Ameril. The Court based the decision on the prosecution’s failure to prove the chain of custody beyond reasonable doubt.

The Supreme Court’s decision in People v. Ameril reinforces the need for strict adherence to procedural rules in drug cases. Law enforcement agencies must ensure that all steps in the chain of custody are properly documented and followed to safeguard the integrity of evidence and uphold the rights of the accused. This ruling serves as a critical reminder of the importance of due process and the presumption of innocence in the Philippine 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: People v. Ameril, G.R. No. 203293, November 14, 2016