In the Philippines, convictions for drug offenses hinge on meticulously preserving the integrity of drug evidence. The Supreme Court, in People v. Romorosa, reiterated that an unbroken chain of custody is vital in drug cases. This means that every transfer of evidence, from seizure to court presentation, must be documented. The court emphasized that even if standard procedures are not strictly followed, the evidence remains valid if its integrity is demonstrably maintained, ensuring reliable convictions and protecting the rights of the accused.

When Does Deviating from Standard Drug Evidence Handling Procedures Affect a Conviction?

The case of People of the Philippines v. Catherine Romorosa y Ostoy revolves around the appellant’s conviction for the illegal sale of dangerous drugs. Romorosa was apprehended during a buy-bust operation conducted by the National Bureau of Investigation (NBI). The central legal question is whether the failure to strictly adhere to standard evidence handling procedures, specifically the non-transfer of seized drugs to an evidence custodian, compromises the integrity of the evidence and warrants an acquittal. The Supreme Court ultimately upheld the conviction, clarifying the extent to which procedural deviations affect the admissibility of drug evidence.

The prosecution presented evidence that a confidential informant arranged a drug deal between SI Fernandez and Omar, leading to a buy-bust operation where Romorosa was caught selling shabu. The defense challenged the credibility of the prosecution’s narrative, citing inconsistencies in SI Fernandez’s testimony and questioning the chain of custody of the seized drugs. Romorosa argued that the drugs presented in court were not reliably identified because they were kept by the forensic chemist, SFC Purificando, rather than being turned over to an evidence custodian, allegedly violating NBI’s standard procedure. This raises questions about the reliability of the process.

The Supreme Court, however, found no significant inconsistencies in the testimony of SI Fernandez. The Court clarified that the apparent contradiction in Fernandez’s affidavit was a matter of semantics, not a fundamental discrepancy in the events described. The Court stated:

As can be seen, the affidavit referenced to SI Fernandez as being able to “close a deal” for the purchase of shabu during the conduct of the buy-bust operation itself. This implies that the affidavit’s use of the phrase “close a deal” was not to connote that it was SI Fernandez who contacted Omar and made prior arrangements for the sale of shabu in Alabang. Rather, the phrase was used in the sense that it was only SI Fernandez who was able to consummate the sale of shabu which had been pre-arranged by the CI.

Building on this principle, the Court addressed the issue of the chain of custody of the seized drugs. The Court referred to its prior ruling in People v. Kamad, elucidating that the essential links in the chain of custody are:

x x x: 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 by the forensic chemist to the court.

The Court found that these links were adequately established in Romorosa’s case. SI Fernandez took possession of the drugs, marked them appropriately, and ensured they were inventoried and photographed. The drugs were then submitted to SFC Purificando, who confirmed their identity as shabu. Purificando stored the drugs in a secure steel cabinet until their presentation in court. The key aspect here is maintaining the integrity of the evidence.

The Court then addressed the appellant’s argument that the forensic chemist’s failure to turn over the drugs to an evidence custodian compromised the chain of custody. It emphasized that neither the law nor jurisprudence mandates any specific intermediary between the forensic chemist and the court. The main concern is whether the integrity of the evidence was maintained throughout the process. Since there was ample evidence that SFC Purificando took proper precautions to safeguard the drugs, the Court concluded that the corpus delicti, or the body of the crime, was proven beyond reasonable doubt.

The Supreme Court emphasized that the integrity of the drug presented to the court is paramount. The Court noted that there was enough evidence to prove that the integrity of the shabu examined was protected from any possibility of contamination or substitution while in his custody. The Court stated:

In view of the foregoing, We are satisfied that the corpus delicti of the offense charged against the appellant was proven beyond reasonable doubt.

This ruling underscores the importance of adhering to proper evidence handling procedures but recognizes that the ultimate concern is maintaining the integrity and identity of the drug evidence. The Court’s decision affirms that strict compliance with every procedural step is not always necessary if the prosecution can demonstrate that the integrity of the evidence was preserved throughout the process. This decision has significant implications for drug-related prosecutions in the Philippines, emphasizing the balance between procedural rigor and substantive justice.

FAQs

What was the key issue in this case?	The key issue was whether the failure to turn over seized drugs to an evidence custodian compromised the integrity of the evidence, thereby warranting an acquittal. The Court focused on whether the integrity of the evidence was maintained regardless of the deviation.
What is the chain of custody in drug cases?	The chain of custody refers to the sequence of transfers of drug evidence, from seizure to presentation in court, each transfer being documented to ensure the integrity of the evidence. The links include seizure, marking, turnover to investigating officer, turnover to forensic chemist, and submission to the court.
Why is the chain of custody important?	It is essential to preserve the integrity and identity of the drug evidence, preventing contamination, alteration, or substitution. A broken chain of custody can raise doubts about the authenticity of the evidence, affecting the outcome of the case.
What did the forensic chemist do in this case?	The forensic chemist, SFC Purificando, examined the seized substances, confirmed they were shabu, and kept them in a locked steel cabinet in his office until he presented them in court. The court found this acceptable because it ensured the integrity of the drugs.
What happens if the chain of custody is broken?	If the chain of custody is broken, the admissibility and credibility of the drug evidence may be challenged. The prosecution must then provide sufficient justification to assure the court that the integrity of the evidence was not compromised.
Was there a violation of procedure in this case?	Yes, there was a deviation from the standard procedure because the drugs were not turned over to an evidence custodian. However, the Supreme Court ruled that this deviation did not automatically invalidate the evidence because its integrity was maintained.
What is the significance of this case?	This case clarifies that while adherence to standard procedures is crucial, the primary concern is preserving the integrity of the drug evidence. It provides guidance on how courts should assess the impact of procedural lapses in drug cases.
What is “corpus delicti”?	Corpus delicti refers to the body of the crime, which in drug cases means proving that the seized substance is indeed an illegal drug. It is a fundamental element that the prosecution must establish beyond reasonable doubt for a conviction.

The Supreme Court’s decision in People v. Romorosa underscores the need for law enforcement to follow proper evidence handling procedures while recognizing that the ultimate goal is to maintain the integrity of drug evidence. This ruling offers valuable guidance on how to strike a balance between procedural adherence and substantive justice, ensuring reliable convictions in drug-related offenses.

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. MOHAMAD DAMPAK Y DISALO @ “LANDO” AND JAMIL DAMPAK Y MIMBALAWAG @ “JAMIL,” ACCUSED. CATHERINE ROMOROSA Y OSTOY @ “LYN,” ACCUSED-APPELLANT., G.R. No. 237209, April 10, 2019