In People v. Angeles, the Supreme Court affirmed the conviction of Joy Angeles for illegal sale and possession of dangerous drugs, emphasizing the importance of adhering to the chain of custody rule in drug-related cases. The Court underscored that even with minor procedural lapses, the integrity and evidentiary value of the seized drugs must be preserved to secure a conviction. This case highlights the necessity for law enforcement to meticulously document each step in handling drug evidence, from seizure to presentation in court, to maintain its admissibility and ensure justice.

From Buy-Bust to Courtroom: Can a Broken Chain of Custody Free a Convicted Drug Offender?

The case of People v. Joy Angeles y Agbolos began with a buy-bust operation conducted by the Lingayen Police Station operatives after a surveillance operation identified Angeles as a drug peddler. On November 19, 2013, a confidential informant contacted Angeles to arrange a drug purchase. PO3 Raul Cayabyab acted as the poseur-buyer, successfully purchasing a sachet of shabu from Angeles using marked money. After the transaction, Angeles was arrested, and a subsequent search revealed two more sachets of shabu in her possession. The seized items were marked, inventoried, and photographed at the scene in the presence of Barangay Kagawad Federico Dizon and Assistant Provincial Prosecutor Jeffrey Catungal.

However, Angeles contested her conviction, primarily arguing that the chain of custody of the drug evidence was compromised. She pointed out that she did not sign the inventory sheet, and a media representative was not present during the marking and inventory of the seized items. Angeles maintained that these lapses created doubts about the integrity of the evidence presented against her. The prosecution countered that Angeles refused to sign the inventory, which was duly noted, and they had made reasonable efforts to secure a media representative, though unsuccessfully. The Regional Trial Court (RTC) found Angeles guilty on both charges, and the Court of Appeals (CA) affirmed this decision.

The central legal question before the Supreme Court was whether the alleged gaps in the chain of custody warranted the acquittal of Angeles. The Supreme Court addressed the issue by reiterating the elements of illegal sale and possession of dangerous drugs. For illegal sale, it was established that (i) Angeles was the seller, and PO3 Cayabyab was the buyer; (ii) the object of the sale was a sachet of shabu; (iii) the consideration was the P500.00 marked money; and (iv) there was delivery of the drug and payment made. As for illegal possession, the prosecution proved that Angeles possessed two heat-sealed sachets containing methamphetamine hydrochloride without legal authorization, and she freely and consciously possessed these illegal drugs.

Building on this, the Court delved into the chain of custody rule as outlined in Section 21 of Republic Act No. 9165 (RA 9165), also known as the Comprehensive Dangerous Drugs Act of 2002, prior to its amendment by RA 10640. Section 21(1) states:

(1) The apprehending team having initial custody and control of the drugs shall, immediately after seizure and confiscation, physically inventory and photograph the same in the presence of the accused or the person/s from whom such items were confiscated and/or seized, or his/her 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 thereof;

The Implementing Rules and Regulations of RA 9165 further elaborate on this, specifying that the inventory and photography should occur at the place of seizure or the nearest police station or office, whichever is practicable. Importantly, the rules also provide a crucial caveat: non-compliance with these requirements is excusable under justifiable grounds, provided the integrity and evidentiary value of the seized items are properly preserved.

The Supreme Court emphasized the four critical links that must be established to ensure compliance with the chain of custody rule. The Supreme Court emphasized the importance of these links, stating, “first, the seizure and marking, if practicable, of the illegal drug recovered from the accused by the apprehending officer; second, the turnover of the illegal drug seized by the apprehending officer to the investigating officer; third, the turnover by the investigating officer of the illegal drug to the forensic chemist for laboratory examination; and fourth, the turnover and submission of the marked illegal drug seized from the forensic chemist to the court.” These links are critical to maintaining the integrity of the evidence.

In this case, the Court found that the prosecution adequately demonstrated compliance with these requirements. PO3 Cayabyab immediately marked the seized items with his initials at the place of the incident and conducted an inventory in the presence of Barangay Kagawad Dizon and Prosecutor Catungal. PO2 Naungayan took pictures of the marking and inventory. The seized sachets were then turned over to PO2 Naungayan, who prepared the request for laboratory examination. PO3 Cayabyab then transported the request and the sachets to the Crime Laboratory, where PCSI Emelda B. Roderos, a Forensic Chemist, received and examined them. PCSI Roderos confirmed that the items tested positive for methamphetamine hydrochloride and that the specimens presented in court were the same ones she had examined.

The Court acknowledged Angeles’ argument regarding the absence of her signature on the inventory sheet and the lack of a media representative during the marking and inventory. However, it noted that the inventory sheet specifically indicated that Angeles refused to sign, and this was corroborated by the police officers’ joint affidavit. As for the media representative, PO3 Cayabyab testified that they contacted reporters from ABS-CBN and GMA, but the ABS-CBN reporter was unavailable, and there was no response from GMA. The Court deemed this explanation sufficient, concluding that the buy-bust team had made reasonable efforts to secure a media representative.

The Supreme Court found that these justifications adequately addressed the procedural lapses, maintaining the admissibility of the evidence. The Court emphasized that the primary concern is to ensure the preservation of the integrity and evidentiary value of the seized drugs. The Court noted that the police officers exerted serious efforts to secure the presence of a media representative during the operation. The failure to do so was justified, given the unavailability of the reporters from the media outlets that the police coordinated with.

FAQs

What were the charges against Joy Angeles?	Joy Angeles was charged with illegal sale and illegal possession of dangerous drugs, specifically methamphetamine hydrochloride (shabu), in violation of Sections 5 and 11 of Republic Act No. 9165.
What is the chain of custody rule in drug cases?	The chain of custody rule requires that the prosecution establish an unbroken trail of accountability for seized drug evidence, from the moment of seizure to its presentation in court, to ensure its integrity and admissibility.
Why did Angeles argue that the chain of custody was broken?	Angeles argued that the chain of custody was broken because she did not sign the inventory of seized items, and a media representative was not present during the inventory and marking of the drugs.
What did the police do to comply with the chain of custody rule?	The police marked and inventoried the seized items at the scene in the presence of an elected public official (Barangay Kagawad) and a representative from the Department of Justice. They also attempted to secure a media representative.
What was the Court’s response to the absence of Angeles’ signature?	The Court noted that Angeles refused to sign the inventory, which was documented by the police. The Court deemed this refusal not to be a fault of the buy-bust team.
How did the Court address the lack of a media representative?	The Court accepted the police’s explanation that they had contacted media representatives who were either unavailable or unresponsive, showing that they made reasonable efforts to comply.
What is the significance of preserving the integrity of the seized drugs?	Preserving the integrity of seized drugs is crucial to ensure that the evidence presented in court is the same substance that was seized from the accused, thereby safeguarding the fairness and accuracy of the legal proceedings.
What penalties were imposed on Angeles?	Angeles was sentenced to life imprisonment and a fine of P500,000 for illegal sale of dangerous drugs, and imprisonment ranging from twelve (12) years and one (1) day to seventeen (17) years, and a fine of P300,000 for illegal possession of prohibited drugs.

In conclusion, People v. Angeles reinforces the principle that while strict adherence to procedural guidelines is ideal, the paramount consideration is whether the integrity and evidentiary value of the seized drugs have been preserved. The Court’s ruling underscores that justifiable reasons for non-compliance with certain procedural requirements can be accepted, provided that the prosecution establishes an unbroken chain of custody and the identity of the drugs beyond reasonable doubt.

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. Angeles, G.R. No. 229099, February 27, 2019