In the case of Antonio Jocson y Cristobal v. People of the Philippines, the Supreme Court acquitted the petitioner due to the prosecution’s failure to adhere to the chain of custody rule in handling seized drug evidence. The Court emphasized that the prosecution must establish an unbroken chain of custody to ensure the integrity and identity of the seized drug, which constitutes the corpus delicti of the offense. This decision underscores the importance of strict compliance with procedural safeguards to protect individual rights and prevent wrongful convictions in drug-related cases, particularly given the severe penalties involved.

Flawed Drug Evidence: Can Doubt Override a Guilty Verdict?

Antonio Jocson was charged with violating Section 11, Article II of Republic Act No. 9165, for allegedly possessing 0.05 gram of methamphetamine hydrochloride, or shabu. The prosecution’s case rested on the testimony of PO2 Robin Rosales Molina, who claimed that Jocson was caught in a buy-bust operation. Jocson, however, denied the charges, claiming he was framed. The Regional Trial Court convicted Jocson, and the Court of Appeals affirmed this decision. The Supreme Court, however, reversed the lower courts’ rulings, focusing on the multiple breaches in the chain of custody of the seized drug.

The Supreme Court emphasized the importance of the chain of custody rule in drug cases, explaining that the drug itself constitutes the corpus delicti of the offense. The prosecution, therefore, has the burden of proving that the substance illegally possessed by the accused is the same substance presented in court. The chain of custody rule ensures the integrity of the seized drug item by accounting for each link in its custody: (1) seizure and marking, (2) turnover to the investigating officer, (3) turnover to the forensic chemist, and (4) submission to the court.

As a method of authenticating evidence, the chain of custody rule requires that the admission of an exhibit be preceded by evidence sufficient to support a finding that the matter in question is what the proponent claims it to be. It would include testimony about every link in the chain, from the moment the item was picked up to the time it is offered into evidence, in such a way that every person who touched the exhibit would describe how and from whom it was received, where it was and what happened to it while in the witness’ possession, the condition in which it was received and the condition in which it was delivered to the next link in the chain. These witnesses would then describe the precautions taken to ensure that there had been no change in the condition of the item and no opportunity for someone not in the chain to have possession of the same.

In this case, the Court identified several critical lapses in the chain of custody. First, the drug item was not marked immediately at the place of seizure. Instead, it was marked later at the SAID-SOTF office by the investigating officer, PO1 del Mundo. This delay and relocation created an opportunity for the evidence to be tampered with or substituted, undermining its integrity. Second, PO2 Molina admitted that the buy-bust team did not prepare an inventory of the seized item, violating the procedural requirements outlined in Section 21 of RA 9165.

Third, the police team also failed to photograph the seized drug item, further compromising the chain of custody. The absence of photographic evidence made it difficult to verify that the item presented in court was the same one seized from Jocson. Finally, the investigator, PO1 del Mundo, who marked the item, did not testify in court. This omission meant that the prosecution failed to establish how the seized item was handled from the time it was received from PO2 Molina until it left his custody.

The Court acknowledged the possibility of a less-than-perfect chain of custody due to varying field conditions, referencing the saving clause in the Implementing Rules and Regulations of RA 9165. This clause allows for leniency if justifiable grounds exist for deviating from established protocol, provided that the integrity and evidentiary value of the seized items are properly preserved. However, PO2 Molina offered no explanation for the buy-bust team’s failure to comply with the chain of custody rule, rendering the saving clause inapplicable.

The Supreme Court rejected the presumption of regularity in the performance of official functions, noting that this presumption cannot substitute for compliance with the chain of custody rule. The Court held that the repeated breaches in the chain of custody cast serious doubt on the identity and integrity of the corpus delicti, warranting Jocson’s acquittal. The Court underscored the importance of strict adherence to procedural safeguards, given the severity of penalties in drug cases and the risk of wrongful convictions. The ruling serves as a reminder of the need for law enforcement to meticulously follow chain of custody protocols to ensure the reliability and admissibility of drug evidence in court.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution sufficiently established an unbroken chain of custody for the seized drug, which is essential for proving the corpus delicti in drug cases.
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 drug evidence, from seizure to presentation in court, to ensure its integrity and identity.
Why is the chain of custody important in drug cases?	It is important because illegal drugs are easily susceptible to tampering, alteration, or substitution. A flawed chain of custody raises doubts about the authenticity and reliability of the evidence.
What are the required steps in the chain of custody?	The steps include seizure and marking, turnover to the investigating officer, turnover to the forensic chemist, and submission to the court.
What are the requirements after seizure and confiscation of drugs?	Immediately after seizure and confiscation, the apprehending team must physically inventory and photograph the drugs in the presence of the accused, a media representative, a DOJ representative, and an elected public official.
What happens if there are gaps in the chain of custody?	Gaps in the chain of custody can lead to the exclusion of the drug evidence, potentially resulting in the acquittal of the accused, as happened in this case.
Can deviations from the chain of custody rule be excused?	Yes, deviations may be excused if there are justifiable grounds and the integrity and evidentiary value of the seized items are properly preserved.
How did the Supreme Court rule in this case?	The Supreme Court acquitted Antonio Jocson, holding that the prosecution failed to establish an unbroken chain of custody, thus casting doubt on the identity and integrity of the seized drug.

This case highlights the critical importance of adhering to the chain of custody rule in drug cases to ensure the integrity of the evidence and protect the rights of the accused. Law enforcement agencies must be diligent in following the required procedures to avoid compromising the evidence and jeopardizing prosecutions. This ruling reinforces the need for meticulous compliance to uphold justice and fairness 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: ANTONIO JOCSON Y CRISTOBAL VS. PEOPLE OF THE PHILIPPINES, G.R. No. 199644, June 19, 2019