The Supreme Court affirmed the conviction of Chih Chien Yang for illegal possession of dangerous drugs, specifically ketamine hydrochloride. The Court clarified that while strict adherence to the chain of custody rule under Republic Act No. 9165 is ideal, deviations are not always fatal, especially when dealing with large quantities of drugs. This decision reinforces the principle that the integrity of evidence is paramount, but procedural lapses may be excused when the amount of seized drugs makes tampering unlikely, ensuring that large-scale drug traffickers are not shielded by minor technicalities.

When a Fingerprint Scanner Unlocks a Drug Conviction

This case revolves around the arrest and conviction of Chih Chien Yang for violating Section 11, Article II of Republic Act No. 9165, also known as the “Comprehensive Dangerous Drugs Act of 2002.” The central question is whether the evidence obtained during a search of Yang’s residence was admissible, considering potential lapses in the chain of custody as prescribed by law. Yang was found in possession of 9.9 kilograms of Ketamine Hydrochloride, a dangerous drug, during the execution of a search warrant. His defense centered on the claim of an illegal arrest and the inadmissibility of the evidence seized.

The events leading to Yang’s arrest began on April 19, 2008, when a team of police officers, armed with a search warrant and an arrest warrant for a previous offense, located Yang driving his vehicle. Upon attempting to stop him, Yang sped off, leading to a chase that ended at the gate of Multinational Village in Parañaque City. After his arrest, the police officers, along with Yang and barangay officials, proceeded to his residence to conduct the search. The search yielded a significant quantity of Ketamine Hydrochloride, found in a locked room accessible only via a fingerprint scanner. This discovery led to Yang’s prosecution and subsequent conviction.

At trial, Yang pleaded not guilty and presented a version of events that differed significantly from the prosecution’s account. He claimed that he was framed and that the police officers had planted the drugs in his vehicle. Yang also alleged that the police officers attempted to extort money from him in exchange for dropping the charges. However, the Regional Trial Court (RTC) found Yang guilty beyond reasonable doubt, a decision that was later affirmed by the Court of Appeals (CA). The RTC and CA both emphasized the presumption of regularity in the performance of official duties by the police officers, and they found Yang’s defenses unconvincing.

One of the critical aspects of this case is the application of Section 21 of RA 9165, which outlines the procedure for the custody and handling of seized drugs. This section mandates that the seized items be marked, inventoried, and photographed immediately after seizure, in the presence of the accused and representatives from the media, the Department of Justice (DOJ), and any elected public official. In Yang’s case, while barangay officials were present, there were no representatives from the media or the DOJ during the initial inventory and photograph-taking. This deviation from the prescribed procedure raised questions about the integrity of the evidence. Section 21 of RA 9165 states:

“(1) The apprehending team having initial custody and control of the drugs shall, immediately after seizure and confiscation, conduct a physical inventory of the seized items 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.”

Despite the procedural lapse, the Supreme Court upheld Yang’s conviction, relying on the principle that the primary concern is the preservation of the corpus delicti – the body of the crime. The Court noted that the large quantity of drugs seized in this case made it unlikely that the evidence had been planted or tampered with. This view aligns with previous jurisprudence, such as People v. Lung Wai Tang, where the Court held that the strict adherence to procedural safeguards is more critical when the quantity of drugs seized is small, as these are more susceptible to tampering.

The Court also emphasized the significance of Yang’s attempt to evade the police officers during the initial encounter. Flight, in legal terms, can be interpreted as an indication of guilt. This behavior, combined with the discovery of a substantial amount of ketamine in his possession, further supported the prosecution’s case. The testimonies of the key prosecution witnesses, Police Officer 3 Jose Nabarte and Philippine Drug Enforcement Agency Chemist Maria Criser Abad, were crucial in establishing the chain of custody. They accounted for the movement and condition of the seized drugs from the time of seizure until their presentation in court.

Furthermore, the Court considered the nature of Ketamine Hydrochloride as a dangerous drug. Citing the World Health Organization (WHO), the Court noted the neurobehavioral effects of ketamine misuse, including anxiety, agitation, and impaired motor functions. The Dangerous Drugs Board had classified ketamine as a dangerous drug in 2005, underscoring its potential for abuse and harm. With the evidence establishing Yang’s possession of the drug and its dangerous nature, the burden shifted to Yang to demonstrate legal authorization, which he failed to do.

In summary, the Supreme Court’s decision in this case underscores the importance of adhering to the chain of custody rule while also recognizing that minor procedural lapses may not invalidate a conviction, especially when the amount of drugs seized is substantial. This ruling serves as a reminder to law enforcement agencies to follow the prescribed procedures diligently, but it also provides a framework for evaluating the admissibility of evidence in drug-related cases, balancing the rights of the accused with the need to combat drug trafficking. The circumstances of the case, including the large quantity of drugs, the accused’s flight, and the testimonies of the officers involved, weighed heavily in the final decision. The court ultimately found that these factors sufficiently established the guilt of the accused beyond a reasonable doubt.

FAQs

What was the key issue in this case?	The key issue was whether the evidence obtained during the search of Chih Chien Yang’s residence was admissible, considering potential lapses in the chain of custody as prescribed by Section 21 of RA 9165.
What is the chain of custody rule?	The chain of custody rule refers to the documented process of tracking seized evidence, ensuring its integrity from the moment of seizure to its presentation in court. It includes procedures for marking, inventorying, and safeguarding the evidence.
What is the “large quantity exception” in drug cases?	The “large quantity exception” suggests that strict adherence to chain of custody rules may be relaxed when a substantial amount of drugs is seized, reducing the likelihood of tampering or planting of evidence.
What was the weight of the Ketamine Hydrochloride found in Yang’s possession?	9.9 kilograms.
What is Ketamine Hydrochloride?	Ketamine Hydrochloride is a dangerous drug that, according to the World Health Organization, causes neurobehavioral effects such as anxiety, agitation, and impaired motor functions, and was classified as such by the Dangerous Drugs Board in 2005.
What witnesses are required during the inventory of seized drugs, according to RA 9165?	Prior to the amendment of RA 9165, the law required the presence of the accused, a representative from the media, a representative from the DOJ, and any elected public official.
What was Yang’s defense in court?	Yang claimed that he was illegally arrested without a warrant, framed by the police, and that the evidence was planted. He also alleged attempted extortion by the police officers.
What was the Court’s final ruling in this case?	The Supreme Court affirmed the lower courts’ decision, finding Yang guilty beyond reasonable doubt of violating Section 11, Article II of RA 9165, and sentenced him to life imprisonment and a fine of P1,000,000.00.

The Supreme Court’s decision in People v. Chih Chien Yang offers valuable insights into the application of chain of custody rules in drug-related cases. While strict compliance with procedural requirements remains crucial, the Court recognizes that the ultimate goal is to ensure justice and prevent large-scale drug traffickers from escaping accountability due to minor technicalities. This ruling underscores the importance of balancing procedural safeguards with the practical realities of drug enforcement.

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. CHIH CHIEN YANG, G.R. No. 227403, October 13, 2021