In Alfredo A. Ramos v. People of the Philippines, the Supreme Court acquitted the petitioner, Alfredo A. Ramos, of illegal possession of dangerous drugs due to the prosecution’s failure to adhere to the strict chain of custody requirements outlined in Republic Act (RA) No. 9165, also known as the “Comprehensive Dangerous Drugs Act of 2002.” The Court emphasized that the integrity and evidentiary value of seized drugs must be preserved meticulously, and any unjustified deviations from the prescribed procedures would cast doubt on the evidence presented. This decision underscores the importance of protecting individual liberties and ensuring that law enforcement follows protocol in drug-related cases.

Missing Witnesses, Compromised Evidence: When Drug Possession Charges Crumble

Alfredo A. Ramos was charged with violating Section 11, Article II of RA 9165, for allegedly possessing 0.05 gram of methamphetamine hydrochloride (shabu). The prosecution claimed that police officers, acting on a tip, caught Ramos in possession of the drug after he attempted to discard a cigarette pack containing it. Ramos denied the charges, stating that he was framed. The Regional Trial Court (RTC) convicted Ramos, a decision upheld by the Court of Appeals (CA). However, the Supreme Court (SC) reversed these rulings, focusing on critical lapses in the chain of custody of the seized drug. The key issue was whether the prosecution adequately proved that the seized drug’s integrity was maintained, considering the police officers’ failure to comply with the witness requirements during the inventory process.

The Supreme Court emphasized that in cases involving illegal possession of dangerous drugs, the prosecution must establish the identity of the drug with moral certainty, forming an integral part of the corpus delicti. This necessitates an unbroken chain of custody, accounting for each link from seizure to presentation in court. Section 21 of RA 9165, prior to its amendment by RA 10640, mandates specific procedures for handling seized drugs, including conducting a physical inventory and photographing the items immediately after seizure. This must occur in the presence of the accused, a media representative, a representative from the Department of Justice (DOJ), and any elected public official.

The purpose of these requirements is to prevent the switching, planting, or contamination of evidence, ensuring the integrity and credibility of the seizure. In People v. Mendoza, the Court highlighted the importance of these witnesses, stating:

“[W]ithout the insulating presence of the representative from the media or the Department of Justice, or any elected public official during the seizure and marking of the [seized drugs], the evils of switching, ‘planting’ or contamination of the evidence… again reared their ugly heads as to negate the integrity and credibility of the seizure and confiscation of the [said drugs] that were evidence herein of the corpus delicti, and thus adversely affected the trustworthiness of the incrimination of the accused.”

While strict compliance may not always be possible, the Implementing Rules and Regulations (IRR) of RA 9165, and later RA 10640, allow for justifiable non-compliance, provided the integrity and evidentiary value of the seized items are preserved. The prosecution must demonstrate justifiable grounds for non-compliance and prove that the integrity of the evidence remained intact. The justifiable ground for non-compliance must be proven as a fact; the Court cannot assume its existence, as reiterated in People v. De Guzman:

“[T]he justifiable ground for non-compliance must be proven as a fact, because the Court cannot presume what these grounds are or that they even exist.”

In the case at hand, SPO1 Medina admitted that the inventory was conducted without the presence of any elected public official or representatives from the DOJ and the media. The justification offered was that no barangay kagawad was available, and despite exerting effort, no media or DOJ representative could be found. The Court found this justification inadequate, emphasizing that mere statements of unavailability, without proof of earnest attempts to contact the required witnesses, are insufficient. As the Court held in People v. Umipang:

“[A] sheer statement that representatives were unavailable without so much as an explanation on whether serious attempts were employed to look for other representatives, given the circumstances is to be regarded as a flimsy excuse.”

The Court reiterated that police officers must convince the Court that they exerted earnest efforts to comply with the mandated procedure and that their actions were reasonable under the given circumstances. Failure to provide justifiable grounds compromises the integrity and evidentiary value of the seized items. Because the prosecution failed to provide such grounds, the Court acquitted Ramos.

The Court acknowledged the government’s campaign against drug addiction but stressed that this campaign cannot override the constitutional rights of individuals. The procedure in Section 21 of RA 9165, as amended, is a matter of substantive law and cannot be dismissed as a mere technicality. Prosecutors have a positive duty to prove compliance with this procedure and to justify any deviations during trial.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution adequately proved an unbroken chain of custody for the seized drugs, especially given the absence of required witnesses during the inventory. The Court focused on the integrity and evidentiary value of the evidence.
What is the chain of custody rule?	The chain of custody rule requires that the prosecution account for each link in the chain of possession of seized drugs, from the moment of seizure to its presentation in court, to ensure the integrity of the evidence. This prevents contamination or substitution.
Who are the required witnesses under Section 21 of RA 9165?	Prior to amendment, Section 21 required the presence of the accused, a media representative, a representative from the DOJ, and any elected public official during the inventory and photographing of seized drugs.
What happens if the police fail to follow Section 21?	Failure to comply with Section 21 can render the seized drugs inadmissible as evidence, unless the prosecution can provide justifiable grounds for the non-compliance and prove that the integrity of the evidence was preserved.
What is considered a justifiable ground for non-compliance?	Justifiable grounds must be proven as a fact and may include the unavailability of witnesses despite earnest efforts to secure their presence, or dangerous circumstances that prevent conducting the inventory at the place of seizure.
What is the role of prosecutors in drug cases?	Prosecutors have a duty to prove compliance with Section 21 and justify any deviations from the procedure during trial. They must ensure the integrity of the evidence and protect the rights of the accused.
Why is the presence of witnesses so important?	The presence of witnesses is intended to prevent the switching, planting, or contamination of evidence, ensuring that the proceedings are free from any taint of illegitimacy or irregularity.
What is the effect of RA 10640 on witness requirements?	RA 10640 amended Section 21, reducing the required witnesses to an elected public official and either a representative from the National Prosecution Service or the media, making compliance somewhat easier.

The Supreme Court’s decision in Ramos v. People reinforces the importance of strict adherence to procedural safeguards in drug-related cases. It serves as a reminder to law enforcement agencies to diligently comply with the requirements of RA 9165 to ensure the integrity of evidence and protect the constitutional rights of the accused.

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: Alfredo A. Ramos v. People, G.R. No. 233572, July 30, 2018