In drug-related cases, the integrity of the evidence is paramount. The Supreme Court has clarified that while using an evidence bag is a good practice, the primary focus should be on how the evidence is handled and transferred between officers. This means maintaining a clear chain of custody is more critical than the specific type of container used. If the chain of custody is properly documented, a conviction can stand even if an evidence bag was not used. This ruling emphasizes the importance of proper procedure and documentation by law enforcement in preserving the integrity of drug evidence.

Beyond the Bag: Ensuring Integrity in Drug Evidence Handling

Amalia Soriano was convicted of illegal possession of 16.9618 grams of shabu. The case hinged on whether the prosecution adequately proved the chain of custody, especially considering the absence of an evidence bag. Soriano argued that the prosecution failed to establish the corpus delicti because the testimonies regarding the chain of custody were inadequate and inconsistent. She pointed out that PO1 Togores, the seizing officer, provided insufficient details on how the seized items were safeguarded, particularly noting the lack of information on whether the items were placed in a secured container or evidence bag. This raised questions about the integrity and evidentiary value of the seized drugs, forming the core of Soriano’s appeal.

The Court of Appeals (CA) affirmed the Regional Trial Court’s (RTC) decision, emphasizing that the chain of custody remained unbroken, and the integrity of the seized drugs was preserved. The CA gave credence to PO1 Togores’ testimony, stating that the drug specimens were in his possession from the moment of seizure until they were handed to the forensic chemist. This underscored the importance of the continuous and documented handling of evidence from the point of confiscation to its presentation in court. Soriano then elevated the case to the Supreme Court, questioning the CA’s decision.

The Supreme Court delved into the history of using evidence bags in drug cases, tracing its origins to the 1999 Philippine National Police Drug Enforcement Manual (1999 PNP Manual), which mandated the use of an evidence bag or envelope to store seized drug items. The manual directed its use not only in buy-bust operations but also in the service of search warrants. With the enactment of Republic Act No. 9165 in 2002, the Dangerous Drugs Board (DDB) also issued regulations regarding the storage of drug evidence. However, the Court noted that these guidelines and regulations, while emphasizing proper handling, did not make the use of an evidence bag an absolute requirement.

Building on this principle, the Supreme Court referenced several cases, including People v. Sanchez, where the Court emphasized the importance of marking seized items and placing them in an envelope or evidence bag. However, this requirement was qualified with the recognition that the type and quantity of the seized items might necessitate different handling or containers. This acknowledgment provided flexibility in handling drug evidence, focusing on the preservation of integrity rather than strict adherence to a specific container type. This approach contrasts with a rigid interpretation that would invalidate drug cases based solely on the absence of an evidence bag.

The Court also highlighted that the 2014 Revised PNP Manual on Anti-Illegal Drugs Operations and Investigation had dispensed with the term “evidence bag” for drug evidence, stating that “[a]ll the illegal drugs … shall be properly marked for identification, weighed when possible or counted, sealed, packed and labeled.” This shift indicated a move towards a more holistic approach, emphasizing proper documentation and handling over the strict use of a specific type of container. Moreover, the Philippine Drug Enforcement Agency (PDEA) guidelines reiterated that noncompliance with the requirements of Section 21(1), Republic Act No. 9165, as amended, would not render seizures void if the integrity and evidentiary value of the seized items were properly preserved.

Drawing from jurisprudence, the Supreme Court cited cases like Tumabini v. People, which emphasized the need to place seized items in an envelope or evidence bag to prevent tampering. However, the Court distinguished the case of Soriano, noting that the 20 heat-sealed plastic sachets of shabu were already contained in four separate containers when they were seized. These containers were marked upon seizure, making the transfer of all specimens into a singular evidence bag less critical. More importantly, the prosecution witnesses’ testimonies established an unbroken chain of custody, reinforcing the integrity of the evidence. The Supreme Court, citing People v. Magayon, reiterated that the testimonies of the arresting officer and the forensic chemist could sufficiently establish every link in the chain of custody, even without the use of an evidence bag.

The High Court, in its decision, emphasized a critical point: the essence of maintaining the integrity of drug evidence lies not in the type of container used, but in the meticulous manner in which the evidence is handled and transferred from one officer to another throughout the chain of custody. This perspective shifts the focus from a mere formality to the practical steps taken to ensure that the evidence remains untainted and reliable. This emphasis ensures that even if a standard evidence bag is not used, the evidentiary value of the seized drugs is preserved through diligent procedures. Moreover, the Supreme Court echoed the ruling in People v. Habana:

Usually, the police officer who seizes the suspected substance turns it over to a supervising officer, who would then send it by courier to the police crime laboratory for testing. Since it is unavoidable that possession of the substance changes hand a number of times, it is imperative for the officer who seized the substance from the suspect to place [their] marking on its plastic container and seal the same, preferably with adhesive tape that cannot be removed without leaving a tear on the plastic container. At the trial, the officer can then identify the seized substance and the procedure he observed to preserve its integrity until it reaches the crime laboratory.

Here, the seized drugs were already contained in heat-sealed plastic packets and marked, and these packets were also contained in marked containers. The prosecution witnesses adequately narrated how these items were carefully handled and transferred from one person to another until they reached the trial court. The Supreme Court recognized the need for a more stringent standard when dealing with minuscule amounts of dangerous drugs, as highlighted in Ramos v. People. However, in this case, the 16.9618 grams of shabu possessed by Soriano hardly qualified as a miniscule amount, further solidifying the decision to uphold her conviction. The Court also acknowledged the ruling in People v. Veloo, stating that for considerable amounts of drugs, the chain of custody rule need not be applied with the same level of strictness as that applied to miniscule amounts.

In conclusion, the Supreme Court upheld Soriano’s conviction but modified the penalty to life imprisonment and a fine of PHP 500,000.00, aligning it with the quantity of drugs involved. The ruling underscores that while following proper procedures is crucial, the absence of a specific container like an evidence bag is not automatically fatal to a drug conviction. The emphasis remains on establishing an unbroken chain of custody and preserving the integrity and evidentiary value of the seized drugs.

FAQs

What was the key issue in this case?	The key issue was whether the failure to use an evidence bag to store seized drug evidence is fatal to a prosecution for illegal possession of dangerous drugs. The court focused on whether the chain of custody was adequately proven, despite the absence of a standard evidence bag.
What is the significance of the chain of custody in drug cases?	The chain of custody is crucial because it ensures the integrity and evidentiary value of the seized drugs. It documents the handling and transfer of the evidence from the moment of seizure to its presentation in court, preventing tampering or substitution.
Is the use of an evidence bag mandatory in all drug cases?	No, the use of an evidence bag is not mandatory. While it is a recommended practice, the Supreme Court has clarified that the primary focus should be on maintaining a clear and unbroken chain of custody.
What happens if there are gaps in the chain of custody?	If there are significant gaps in the chain of custody, it can cast doubt on the integrity of the evidence. This may lead to the acquittal of the accused because the prosecution must prove beyond a reasonable doubt that the seized drugs are the same ones presented in court.
What did PO1 Togores’ testimony establish in this case?	PO1 Togores’ testimony established that he maintained possession of the drug specimens from the moment of seizure until they were handed to the forensic chemist. This continuity of possession was a critical factor in the court’s decision.
How did the presence of the drugs in existing containers affect the ruling?	The fact that the shabu was already contained in heat-sealed plastic packets inside marked containers was significant. It minimized the need for an additional evidence bag because the existing containers already provided a degree of security and traceability.
What was the Court’s rationale for modifying the penalty?	The Court modified the penalty to life imprisonment and a fine of PHP 500,000.00 to align it with the quantity of drugs involved. Section 11 of Republic Act No. 9165 prescribes this penalty for possession of 10 grams or more but less than 50 grams of shabu.
What is the key takeaway from this case for law enforcement?	The key takeaway is that while using an evidence bag is a good practice, maintaining a meticulous and well-documented chain of custody is more critical. Proper handling, marking, and documentation are essential to preserving the integrity of drug evidence.

This case reinforces the principle that procedural compliance, while important, should not overshadow the ultimate goal of preserving the integrity of evidence. The focus on the chain of custody ensures that the pursuit of justice is not derailed by minor technicalities, provided that the core principles of evidence handling are upheld.

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. AMALIA SORIANO, G.R. No. 257747, February 05, 2025