In People v. Angelita Reyes and Josephine Santa Maria, the Supreme Court acquitted Josephine Santa Maria of illegal drug sale due to the prosecution’s failure to prove her guilt beyond a reasonable doubt. The Court emphasized the crucial importance of maintaining an unbroken chain of custody for seized drug evidence, particularly the necessity of having representatives from the media and the National Prosecution Service present during the inventory process, unless justifiable reasons for their absence are provided. This ruling reinforces the protection of individual liberties and highlights the need for strict adherence to procedural safeguards in drug-related cases to prevent wrongful convictions.

The Missing Witnesses: Did the Buy-Bust Operation Meet Legal Scrutiny?

The case originated from a buy-bust operation conducted by the Galas Police Station in Quezon City, prompted by a confidential informant’s tip about drug activities involving Angelita Reyes, also known as “Babang.” During the operation, PO2 Talosig acted as the poseur-buyer and purchased a sachet of suspected shabu from Reyes. Josephine Santa Maria was also apprehended, as she was present during the transaction and received the marked money. Both Reyes and Santa Maria were subsequently charged with violation of Section 5, Article II of Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002.

Following their arrest, the seized evidence was marked, inventoried, and photographed. However, the inventory was only signed by Kagawad Balignasan, and the marking, inventory, and photographing of the seized item were conducted without the presence of counsel for the accused, or representatives from the media and the National Prosecution Service. The Regional Trial Court (RTC) convicted both Reyes and Santa Maria, a decision affirmed by the Court of Appeals (CA). Santa Maria then appealed to the Supreme Court, arguing that her guilt was not proven beyond a reasonable doubt and that the evidence against her was inadmissible due to an invalid warrantless search and arrest. Unfortunately, Reyes passed away while the appeal was pending, leading to the dismissal of her appeal. The central issue before the Supreme Court was whether the prosecution had sufficiently established the chain of custody of the seized drugs, thereby proving Santa Maria’s guilt beyond a reasonable doubt.

The Supreme Court analyzed the requirements for proving illegal sale of prohibited drugs under Article II, Section 5 of R.A. No. 9165. The court reiterated that to secure a conviction, the prosecution must establish the identity of the buyer and seller, the object of the sale, its consideration, and the delivery of the thing sold and the payment made. The Court emphasized that the seized illicit drugs constitute the corpus delicti of the charges and that their identity must be established beyond a reasonable doubt. In People v. Gatlabayan, the Court held that it is crucial that the substance bought during the buy-bust operation is exactly the same substance offered in evidence before the court.

In illegal sale, the illicit drugs confiscated from the accused comprise the corpus delicti of the charges.^[11] In People v. Gatlabayan,^[12] the Court held that it is of paramount importance that the identity of the dangerous drug be established beyond reasonable doubt; and that it must be proven with certitude that the substance bought during the buy-bust operation is exactly the same substance offered in evidence before the court.

The concept of the chain of custody is vital in drug-related cases to ensure that the integrity and identity of the seized drugs are preserved from the moment of confiscation to their presentation in court. Section 21(1) of R.A. No. 9165 and its Implementing Rules and Regulations (IRR) outline the procedures for maintaining this chain. These provisions require the apprehending team to conduct a physical inventory and photograph the seized items immediately after seizure and confiscation. This must be done in the presence of the accused, or their representative or counsel, a representative from the media, a representative from the Department of Justice (DOJ), and any elected public official, all of whom must sign the inventory.

The Court noted that while R.A. No. 10640, which amended R.A. No. 9165, incorporated a saving clause allowing for non-compliance with these requirements under justifiable grounds, the original provisions of Section 21 and its IRR applied to this case, as the alleged crime was committed before the amendment. The Court scrutinized the CA’s finding that the chain of custody was adequately followed despite the absence of media and DOJ representatives during the inventory. The CA had reasoned that the integrity and evidentiary value of the seized evidence were duly accounted for and preserved, and that the absence of counsel was explained by the fact that the appellants did not have counsel at that time.

However, the Supreme Court disagreed, emphasizing that the prosecution failed to provide justifiable grounds for the absence of the required witnesses during the inventory. The Court stressed that the prosecution bears the burden of proving a valid cause for non-compliance with the procedure laid down in Section 21 of R.A. No. 9165. The prosecution must demonstrate that it acknowledged and justified any deviations from the requirements of the law during the trial court proceedings.

The Court articulated several examples of justifiable grounds for omitting certain requirements, such as the unavailability of media representatives or the lack of time to alert them due to the immediacy of the operation, particularly in remote areas. Another justification could be the failure to find an available representative of the National Prosecution Service, or time constraints due to the urgency of the operation and the need to comply with Article 125 of the Revised Penal Code regarding the timely delivery of prisoners. The Court reiterated that a stricter adherence to Section 21 is required when the quantity of illegal drugs seized is minuscule, as it is highly susceptible to planting, tampering, or alteration.

Certainly, the prosecution bears the burden of proof to show valid cause for non-compliance with the procedure laid down in Section 21 of R.A. No. 9165, as amended.^[26] It has the positive duty to demonstrate observance thereto in such a way that, during the proceedings before the trial court, it must initiate in acknowledging and justifying any perceived deviations from the requirements of the law.^[27]

Because the prosecution failed to provide any justifiable reason for the non-compliance with Section 21 of R.A. No. 9165, the Court concluded that the identity of the seized item had not been established beyond a reasonable doubt. The Court thus acquitted Josephine Santa Maria, underscoring the importance of protecting individual liberties and ensuring that all reasonable doubts are resolved in favor of the accused.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution sufficiently established the chain of custody of the seized drugs, as required by Section 21 of R.A. No. 9165, to prove the accused’s guilt beyond a reasonable doubt.
What is the chain of custody rule in drug cases?	The chain of custody rule requires law enforcement to meticulously document and preserve the integrity of seized drug evidence from the point of confiscation to its presentation in court, ensuring that the substance tested and presented is the same one seized from the accused. This includes proper handling, storage, labeling, and transfer of evidence.
Who should be present during the inventory of seized drugs according to R.A. No. 9165?	According to the original provisions of R.A. No. 9165, the inventory and photographing of seized drugs should be done in the presence of the accused (or their representative/counsel), a representative from the media, a representative from the Department of Justice (DOJ), and an elected public official.
What happens if the required witnesses are not present during the inventory?	The Supreme Court held that the prosecution must provide justifiable reasons for the absence of any of the required witnesses. Failure to do so can cast doubt on the integrity of the seized evidence and may lead to the acquittal of the accused.
What are some justifiable reasons for non-compliance with Section 21 of R.A. No. 9165?	Justifiable reasons may include the unavailability of media representatives, the lack of time to alert them due to the immediacy of the operation, the failure to find an available representative from the National Prosecution Service, or time constraints due to the urgency of the operation and the need to comply with Article 125 of the Revised Penal Code.
Why is the presence of media and DOJ representatives important during the inventory?	Their presence is intended to ensure transparency and prevent the planting of evidence or frame-ups, thereby protecting the rights of the accused and maintaining the integrity of the legal process.
What was the Supreme Court’s ruling in this case?	The Supreme Court reversed the decision of the lower courts and acquitted Josephine Santa Maria due to the prosecution’s failure to establish an unbroken chain of custody for the seized drugs, particularly the absence of media and DOJ representatives during the inventory without justifiable reasons.
What is the significance of this ruling?	The ruling underscores the importance of strict compliance with the procedural safeguards outlined in R.A. No. 9165 to protect individual liberties and ensure fair trials in drug-related cases. It emphasizes the prosecution’s burden to justify any deviations from these procedures.

The Supreme Court’s decision in People v. Angelita Reyes and Josephine Santa Maria serves as a crucial reminder of the importance of adhering to the procedural safeguards outlined in R.A. No. 9165. By prioritizing the protection of individual rights and requiring strict compliance with the chain of custody rule, the Court reinforces the need for transparency and accountability in drug-related cases, ensuring that justice is served fairly and equitably.

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, PLAINTIFF-APPELLEE, v. ANGELITA REYES Y GINOVE AND JOSEPHINE SANTA MARIA Y SANCHEZ, ACCUSED-APPELLANTS, G.R. No. 219953, April 23, 2018