In the case of *People of the Philippines v. Alexander Alvaro and Rosalie Geronimo*, the Supreme Court acquitted the accused due to the prosecution’s failure to maintain an unbroken chain of custody over the seized drugs. This decision underscores the critical importance of strictly adhering to procedural safeguards in handling drug evidence, ensuring that the integrity and identity of the drugs are preserved from the moment of seizure to their presentation in court. Without a meticulously documented chain of custody, doubts arise that can undermine a conviction, protecting individuals from potential miscarriages of justice.

When Discrepancies Derail Drug Convictions: Alvaro and Geronimo’s Fight for Freedom

This case revolves around the arrest and subsequent conviction of Alexander Alvaro and Rosalie Geronimo for drug-related offenses. The prosecution alleged that Geronimo sold a sachet of shabu to a poseur-buyer, while Alvaro acted as her accomplice. A separate charge was filed against Geronimo for possessing another sachet of the same drug. The trial court found both accused guilty, a decision that was initially affirmed by the Court of Appeals. However, the Supreme Court took a closer look at the evidence, specifically scrutinizing the handling of the confiscated drugs. The central question became: Did the police follow proper procedures to ensure the integrity and identity of the seized drugs, thereby establishing guilt beyond a reasonable doubt?

The Supreme Court meticulously examined the records and found significant lapses and inconsistencies in the prosecution’s account of how the seized drugs were handled. According to Section 21, Article II of Republic Act No. 9165, also known as the “Comprehensive Dangerous Drugs Act of 2002”, the apprehending team must follow a strict procedure to maintain the chain of custody. This procedure includes conducting a physical inventory and photographing the seized items immediately after seizure and confiscation, in the presence of the accused, a representative from the media, a representative from the Department of Justice (DOJ), and an elected public official.

The law emphasizes the importance of documenting every step to prevent any doubts about the authenticity and integrity of the evidence. The Supreme Court has consistently held that the chain of custody rule is essential to ensure that the drugs presented in court are the same ones seized from the accused. Any unexplained break in the chain can raise reasonable doubt and jeopardize the prosecution’s case. As emphasized in the decision:

Notably, however, in order to secure a conviction for the foregoing crimes, it remains essential that the identity of the confiscated drugs be established beyond reasonable doubt. To obviate any unnecessary doubts on the identity of the dangerous drugs, the prosecution has to show an unbroken chain of custody over the same. It must be able to account for each link in the chain of custody over the dangerous drug, from the moment of seizure up to its presentation in court as evidence of the corpus delicti.

In this case, the Court identified several critical flaws in the prosecution’s handling of the drug evidence. Firstly, there was conflicting testimony regarding the place of marking and inventory of the seized items. Operative Juan S. Siborboro, Jr. testified that he marked the items at the place of arrest, while PO3 Rafael J. Castillo claimed the inventory was conducted along EDSA due to the crowded environment at the Laperal Compound. This inconsistency cast doubt on the reliability of the officers’ accounts.

Secondly, the prosecution failed to establish that the inventory was made in the presence of the accused or the required witnesses. While Barangay Chairman Ernesto Bobier signed the inventory receipt, Siborboro admitted that Bobier was not present during the preparation of the inventory. This non-compliance with the witness requirement further weakened the prosecution’s case. As outlined in Section 21 of RA 9165:

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 (DOJ), and any elected public official who shall be required to sign the copies of the inventory and be given a copy of the same; also, the seized drugs must be turned over to the PNP Crime Laboratory within twenty four (24) hours from confiscation for examination.

Thirdly, the prosecution failed to present any photographs of the seized items, despite PO3 Castillo’s testimony that photographs were taken. This omission created another gap in the evidence, as there was no visual confirmation of the seized drugs and the circumstances of their seizure. Furthermore, there was a discrepancy in the marking of the sachets. The sachet subject of the sale was allegedly marked as “JSJR,” while the sachet confiscated from Geronimo was marked as “JSJR-1.” However, the crime laboratory report indicated that the forensic chemist examined two sachets marked “JSJRND” and “JSJR-1.” The prosecution failed to explain the origin of the “JSJRND” sachet or the whereabouts of the “JSJR” sachet after it was left in the custody of PO1 Randy C. Santos.

Finally, the records revealed that the request for laboratory examination was not delivered by PO1 Santos, but by a certain Serrano. The prosecution failed to explain how Serrano came to possess the seized items, creating another unexplained break in the chain of custody. These multiple lapses and inconsistencies led the Supreme Court to conclude that the integrity and evidentiary value of the seized drugs had been compromised.

The Supreme Court emphasized that the prosecution bears the burden of proving an unbroken chain of custody, and any reasonable doubt on the identity of the drugs seized from the accused must result in their acquittal. In this case, the numerous unexplained departures from the established procedure set forth in Section 21 of RA 9165 created reasonable doubt, leading to the acquittal of Alvaro and Geronimo. This ruling underscores the importance of meticulous adherence to procedural safeguards in drug cases, protecting individuals from wrongful convictions and ensuring the integrity of the justice system. Strict compliance with the chain of custody rule is not merely a technicality; it is a fundamental requirement that safeguards the rights of the accused and ensures the reliability of evidence.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution had established an unbroken chain of custody over the seized drugs, ensuring their integrity and identity from seizure to presentation in court. The Supreme Court found significant lapses in the prosecution’s handling of the evidence.
What is the chain of custody rule in drug cases?	The chain of custody rule requires law enforcement officers to meticulously document every step in the handling of seized drugs. This includes the seizure, marking, inventory, storage, and examination of the drugs to ensure they are the same substances presented in court.
What are the requirements for a valid inventory under RA 9165?	RA 9165 requires that immediately after seizure, a physical inventory of the drugs must be conducted and photographed in the presence of the accused, a media representative, a DOJ representative, and an elected public official. These individuals must sign the inventory, and be given a copy.
Why is the presence of witnesses important during the inventory?	The presence of witnesses is crucial to ensure transparency and prevent any allegations of tampering or planting of evidence by law enforcement officers. Their presence helps maintain the integrity of the process.
What happens if there are discrepancies in the marking of the seized drugs?	Discrepancies in the marking of seized drugs can raise reasonable doubt about the identity of the evidence. The prosecution must provide a credible explanation for the discrepancies to avoid jeopardizing the case.
What is the effect of non-compliance with Section 21 of RA 9165?	Non-compliance with Section 21 of RA 9165 can render the seized drugs inadmissible as evidence, potentially leading to the acquittal of the accused. The prosecution must justify any deviations from the prescribed procedure.
What is the role of the forensic chemist in drug cases?	The forensic chemist examines the seized substances to determine their chemical composition and confirm whether they are dangerous drugs. Their testimony is crucial in establishing the nature of the seized substances.
What is the standard of proof in criminal cases involving dangerous drugs?	In criminal cases involving dangerous drugs, the prosecution must prove the guilt of the accused beyond a reasonable doubt. This requires presenting credible and reliable evidence that establishes all the elements of the crime.
What happens if the chain of custody is broken?	If the chain of custody is broken, it casts doubt on the integrity and identity of the evidence. This can lead to the exclusion of the evidence and the acquittal of the accused, as happened in this case.

The Supreme Court’s decision in *People v. Alvaro and Geronimo* serves as a stern reminder of the importance of adhering to procedural safeguards in drug cases. The meticulous requirements of the chain of custody rule are not mere technicalities, but essential components of a fair and just legal process. By ensuring the integrity and reliability of drug evidence, the courts protect the rights of the accused and uphold the principles of due process.

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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: THE PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. ALEXANDER ALVARO Y DE LEON AND ROSALIE GERONIMO Y MADERA, ACCUSED-APPELLANTS., G.R. No. 225596, January 10, 2018