In People v. Sarabia, the Supreme Court acquitted Dennis Sarabia y Reyes of drug-related charges, emphasizing the critical importance of maintaining an unbroken chain of custody for seized drug evidence. This decision underscores the strict procedural safeguards required in drug cases to protect individual rights and ensure the integrity of evidence. It serves as a reminder that the war on drugs must be waged within the bounds of the law, respecting constitutional rights and established procedures.

When Procedure Protects: How a Faulty Drug Case Led to Acquittal

The case revolves around the arrest of Dennis Sarabia y Reyes for allegedly selling and possessing methamphetamine hydrochloride, commonly known as shabu, during a buy-bust operation. Sarabia was charged with violating Sections 5 and 11, Article II of Republic Act No. (RA) 9165, also known as “The Comprehensive Dangerous Drugs Act of 2002”. The prosecution presented testimonies claiming Sarabia sold a sachet containing 0.0392 gram of shabu and possessed six additional sachets containing 3.219 grams of the same substance. Sarabia vehemently denied these allegations, claiming he was merely arrested without any prior illegal activity.

The Regional Trial Court (RTC) found Sarabia guilty beyond reasonable doubt, a decision subsequently affirmed by the Court of Appeals (CA). However, the Supreme Court reversed these decisions, acquitting Sarabia due to significant lapses in the prosecution’s handling of the evidence. The Court focused on the chain of custody rule, which is vital in ensuring that the substance presented in court is the same one seized from the accused.

In drug cases, the dangerous drug itself is the very corpus delicti, or body of the crime. This makes establishing the integrity of the specimen imperative. Therefore, compliance with the chain of custody rule is crucial in establishing the accused’s guilt beyond reasonable doubt. The chain of custody rule requires a duly recorded authorized movements and custody of seized drugs from the time of seizure to presentation in court.

The links that should be established are: first, the seizure and marking of the illegal drug by the apprehending officer; second, the turnover of the illegal drug 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.

The Supreme Court found critical flaws in the prosecution’s case, particularly in the handling of the drug specimens by the forensic chemist, PI Navarro. Instead of presenting PI Navarro to testify on the transmittal and examination of the seized drug specimens, the prosecution submitted a document entitled “Proffer Testimony (Police Inspector Amiely Ann L. Navarro),” executed by the Assistant City Prosecutor Daryl U. Fajardo (ACP Fafardo). This document was admitted by the RTC, despite objections from the defense.

The Supreme Court emphasized that the “Proffer Testimony” was hearsay evidence, as ACP Fajardo’s statements were beyond his personal knowledge. The Court cited the Rules of Court and previous jurisprudence, noting that a witness can only testify to facts derived from his own perception. The court noted that documents such as affidavits are generally classified as hearsay evidence. This lack of proper testimony and authentication of the Initial Laboratory Report fatally undermined the prosecution’s case, casting serious doubt on the identity and integrity of the corpus delicti.

Furthermore, the Court highlighted the authorities’ failure to adhere to the mandatory procedural requirements outlined in Section 21 of RA 9165. This section details the proper handling, inventory, and documentation of seized drugs. Crucially, it requires the presence of the accused, a media representative, a Department of Justice (DOJ) representative, and an elected public official during the physical inventory and photographing of the seized items immediately after seizure.

Section 21 of RA 9165 states:

SEC. 21. Custody and Disposition of Confiscated, Seized, and/or Surrendered Dangerous Drugs, Plant Sources of Dangerous Drugs, Controlled Precursors and Essential Chemicals, Instruments/Paraphernalia and/or Laboratory Equipment. – The PDEA shall take charge and have custody of all dangerous drugs, plant sources of dangerous drugs, controlled precursors and essential chemicals, as well as instruments/paraphernalia and/or laboratory equipment so confiscated, seized and/or surrendered, for proper disposition in the following manner:

(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 Court emphasized that the presence of these witnesses is necessary to protect against the possibility of planting, contamination, or loss of the seized drug. In this case, the buy-bust team only coordinated with barangay officials and a cameraman, neglecting to secure a DOJ representative. Additionally, the marking of the evidence, a critical step in identifying the drug specimen, was conducted without the presence of any of the required witnesses. This deviation from procedure further compromised the integrity of the evidence.

The Court acknowledged the “saving clause” in the Implementing Rules and Regulations (IRR) of RA 9165, which allows for non-compliance with the required procedures under justifiable grounds, provided the integrity and evidentiary value of the seized items are preserved. However, the prosecution failed to recognize and justify these lapses, undermining the integrity of the corpus delicti. As the Court stated in People v. Reyes:

To warrant the application of this saving mechanism, however, the Prosecution must recognize the lapse or lapses, and justify or explain them. Such justification or explanation would be the basis for applying the saving mechanism. Yet, the Prosecution did not concede such lapses, and did not even tender any token justification or explanation for them. The failure to justify or explain underscored the doubt and suspicion about the integrity of the evidence of the corpus delicti. With the chain of custody having been compromised, the accused deserves acquittal.

Because the prosecution failed to meet the strict standards for handling drug evidence, the Supreme Court had no choice but to acquit Sarabia. This case serves as a crucial reminder that the war on drugs must be conducted within the framework of the law. Failure to adhere to mandatory procedural safeguards jeopardizes the integrity of evidence and undermines the pursuit of justice.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution adequately proved the guilt of Dennis Sarabia for illegal sale and possession of dangerous drugs beyond a reasonable doubt, considering the chain of custody of the seized drugs and compliance with mandatory procedural requirements.
What is the chain of custody rule?	The chain of custody rule refers to the duly recorded authorized movements and custody of seized drugs from the time of seizure/confiscation to receipt in the forensic laboratory, to safekeeping, to presentation in court, until their destruction. It ensures the integrity and identity of the evidence.
Why is the chain of custody so important in drug cases?	In drug cases, the dangerous drug itself is the very corpus delicti or body of the crime. Therefore, it is essential to establish that the substance presented in court is the same one that was seized from the accused, and maintaining the chain of custody ensures this.
What are the requirements under Section 21 of RA 9165?	Section 21 of RA 9165 requires that the seized items be inventoried and photographed immediately after seizure or confiscation in the presence of the accused, a media representative, a DOJ representative, and an elected public official. All of whom shall be required to sign the copies of the inventory and be given a copy thereof.
What happens if there are lapses in following Section 21 of RA 9165?	Non-compliance with the requirements of Section 21 can be excused if the prosecution recognizes the lapses and provides a justifiable reason for them, while also demonstrating that the integrity and evidentiary value of the seized items were properly preserved.
Why was the “Proffer Testimony” inadmissible in court?	The “Proffer Testimony” was considered inadmissible hearsay because it was executed by the Assistant City Prosecutor, whose statements about the transmittal and examination of the drug specimens were beyond his personal knowledge.
What was the court’s final decision in this case?	The Supreme Court reversed the decisions of the lower courts and acquitted Dennis Sarabia of the crimes charged. The acquittal was based on the prosecution’s failure to establish an unbroken chain of custody for the drug specimens and the police officers’ unjustified non-observance of Section 21 of RA 9165.
What is the practical implication of this ruling?	This ruling reinforces the importance of strict adherence to procedural safeguards in drug cases. It highlights the need for law enforcement to meticulously follow the chain of custody rule and the requirements of Section 21 of RA 9165 to ensure the integrity of evidence and protect the rights of the accused.

This case underscores the judiciary’s role in safeguarding individual liberties and upholding the rule of law, even in the face of pressing societal concerns like illegal drugs. The Supreme Court’s decision serves as a stern reminder that shortcuts and disregard for established procedures are unacceptable in the pursuit of justice.

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, VS. DENNIS SARABIA Y REYES, G.R. No. 243190, August 28, 2019