In People v. Marcelo Sanchez, the Supreme Court acquitted the accused due to reasonable doubt, highlighting the critical importance of maintaining an unbroken chain of custody in drug-related cases. The Court emphasized that any unexplained discrepancy in the markings of seized drugs casts doubt on the identity of the corpus delicti, which is fatal to the prosecution’s case. This decision underscores the necessity for law enforcement to meticulously document and preserve the integrity of evidence from the point of seizure to its presentation in court, ensuring that the accused’s rights are protected and the conviction is based on solid, irrefutable evidence.

Lost in Translation: When a Mismarked Sachet Undermines a Drug Bust

Marcelo Sanchez was charged with selling 0.06 grams of shabu in Quezon City. The prosecution presented a buy-bust operation where PO1 Ignacio allegedly purchased the drugs from Sanchez, who was known as “Kiting.” However, conflicting testimonies and discrepancies in the evidence’s markings led to the Supreme Court overturning the lower courts’ guilty verdict. The central legal question revolved around whether the prosecution adequately established the chain of custody for the seized drugs, and whether the inconsistent markings on the evidence created reasonable doubt about its authenticity.

To secure a conviction for illegal sale of dangerous drugs, the prosecution must prove the identity of the buyer and seller, the object of the sale, its consideration, the delivery of the thing sold, and the payment. As the Supreme Court explained, “What is important is that the sale transaction of drugs actually took place and that the object of the transaction is properly presented as evidence in court and is shown to be the same drugs seized from the appellant.” The seized drug itself is considered the corpus delicti or the body of the crime, and its integrity must be preserved throughout the legal process.

The **chain of custody** is a crucial aspect of drug cases, ensuring that the evidence presented in court is the same substance seized from the accused. This chain involves the documented authorized movements and custody of seized drugs at each stage, from seizure to presentation in court. Section 1(b) of Dangerous Drugs Board Regulation No. 1, Series of 2002, defines the chain of custody as:

Chain of Custody means the duly recorded authorized movements and custody of seized drugs or controlled chemicals or plant sources of dangerous drugs or laboratory equipment of each stage, from the time of seizure/confiscation to receipt in the forensic laboratory to safekeeping to presentation in court for destruction. Such record of movements and custody of seized item shall include the identity and signature of the person who held temporary custody of the seized item, the date and time when such transfer of custody were made in the course of safekeeping and use in court as evidence, and the final disposition.

The first critical step in this chain is the **marking of the seized item**, as this provides the reference point for all subsequent handlers of the evidence. The marking should occur immediately after seizure, if practicable, to ensure the integrity of the evidence. In this case, while the prosecution presented evidence of a buy-bust operation, retrieval of marked money, photo evidence, and laboratory reports, a significant discrepancy emerged regarding the markings on the seized shabu.

The Joint Affidavit of Arrest, the Inventory of Seized Items, the Initial Laboratory Report, and the Chemistry Report all indicated that the seized sachet was marked with “AI-MS”. PO1 Bautista also testified that the sachet was marked with “AI-MS,” signifying Aldrin Ignacio and Marcelo Sanchez. However, PO1 Ignacio, the poseur-buyer and arresting officer, testified that he marked the specimen only with his initials “AI”.

This inconsistency was never reconciled by the prosecution. The Supreme Court highlighted the importance of this discrepancy, stating, “There is now doubt whether the sachet marked with ‘AI,’ as testified to by the very witness who placed the said marking, was the same sachet marked with ‘AI-MS’ which was brought to the crime laboratory and ultimately presented in court.” The failure to clarify this difference created a reasonable doubt about the integrity of the evidence, ultimately undermining the prosecution’s case.

The chain of custody involves four crucial links: (1) seizure and marking, (2) turnover to the investigating officer, (3) turnover to the forensic chemist, and (4) submission of the marked drug to the court. The marking stage is particularly vital because it separates the evidence from other similar items, preventing switching, planting, or contamination.

Even when subsequent links in the chain of custody are established, a reasonable doubt about the initial marking can break the chain. The Supreme Court referenced the case of People v. Garcia, where similar inconsistencies in markings led to the acquittal of the accused. The Court emphasized that unexplained discrepancies in the markings of seized drugs are not trivial matters, but rather significant lapses that can be fatal to the prosecution’s case.

The Supreme Court’s decision underscores the high standard of proof required in drug cases. Any persistent doubt about the identity of the drug necessitates acquittal. The prosecution must establish the identity of the prohibited drug with moral certainty, ensuring that the substance possessed or sold is the same substance presented in court as evidence.

The Court ultimately granted the appeal, reversed the Court of Appeals’ decision, and acquitted Marcelo Sanchez due to reasonable doubt. The ruling reinforces the importance of meticulous adherence to chain of custody procedures and accurate evidence handling in drug-related cases.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution adequately established an unbroken chain of custody for the seized drugs, considering discrepancies in the markings of the evidence. This inconsistency raised doubts about the authenticity and integrity of the drug presented in court.
What is the significance of the “chain of custody” in drug cases?	The chain of custody ensures that the evidence presented in court is the same substance seized from the accused. It documents every step of the handling process, from seizure to analysis and presentation, to prevent contamination or substitution.
Why was the discrepancy in markings so important?	The discrepancy in the markings raised doubts about whether the substance tested and presented in court was the same one seized from the accused. This doubt undermined the integrity of the evidence and the prosecution’s case.
What is “corpus delicti”?	“Corpus delicti” refers to the body of the crime, which in drug cases is the seized illegal substance itself. Its identity and integrity must be proven beyond reasonable doubt to secure a conviction.
What was PO1 Ignacio’s role in the case?	PO1 Ignacio was the poseur-buyer in the buy-bust operation who allegedly purchased the shabu from Marcelo Sanchez. He was responsible for marking the seized item, but his testimony conflicted with other evidence regarding those markings.
What did the Court mean by “reasonable doubt”?	Reasonable doubt means that, based on the evidence presented, the court has a legitimate uncertainty about the accused’s guilt. If such doubt exists, the accused must be acquitted, even if they seem likely to be guilty.
What happens to Marcelo Sanchez now?	Marcelo Sanchez was acquitted, and the Director of the Bureau of Corrections was ordered to release him immediately, unless he was being held for other lawful reasons. This means he is no longer considered guilty of the crime he was charged with.
What can law enforcement learn from this case?	Law enforcement must meticulously document and preserve the integrity of evidence, especially in drug cases. Accurate marking, proper handling, and a clear chain of custody are essential to ensure convictions are based on solid evidence.

This case serves as a critical reminder of the stringent requirements for evidence handling in drug-related prosecutions. The Supreme Court’s emphasis on maintaining an unbroken chain of custody and accurately marking seized items underscores the importance of protecting the rights of the accused and ensuring that convictions are based on solid, irrefutable evidence. The ruling highlights the necessity for law enforcement to meticulously document and preserve the integrity of evidence from the point of seizure to its presentation in court.

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. Sanchez, G.R. No. 221458, September 05, 2018