Tag: corpus delicti

When Copies Count: Admissibility of Duplicate Evidence in Philippine Courts

In a significant ruling, the Supreme Court of the Philippines clarified the admissibility of duplicate documents as evidence. The Court held that a duplicate, including a photocopy, is admissible to the same extent as the original unless a genuine question is raised about the original’s authenticity, or it would be unjust to admit the duplicate. This decision streamlines evidentiary procedures, allowing courts to consider duplicates of electronic data, electronic documents, and paper-based documents without strict requirements for original submission, thereby promoting efficiency in legal proceedings and easing evidentiary burdens.

Justice Served: When a Death Certificate Photocopy Speaks Volumes in a Murder Trial

The case of People of the Philippines v. Ybo Lastimosa (G.R. No. 265758) centered on the murder of Ildefonso Vega, Jr. The prosecution presented a photocopy of Vega’s death certificate to prove his death, a crucial element of the crime. The accused, Lastimosa, argued that the photocopy was inadmissible as evidence and, therefore, the prosecution failed to prove the corpus delicti—the body of the crime. This challenge raised a fundamental question: In Philippine jurisprudence, can a photocopy serve as valid proof of death in a murder case?

The Supreme Court tackled the issue head-on, tracing the historical evolution of the **Best Evidence Rule** in Philippine law. Initially, the rule strictly required the submission of original documents, permitting secondary evidence only under specific exceptions. Over time, this rule evolved, especially with the introduction of the **Rules on Electronic Evidence**, which recognized duplicates of electronic documents as equivalent to originals under certain conditions.

The Court noted the significant changes introduced by the **2019 Revised Rules on Evidence**, which modified the Best Evidence Rule to the **Original Document Rule**. Rule 130, Section 4(c) of these revised rules explicitly states that “[a] duplicate is admissible to the same extent as an original unless (1) a genuine question is raised as to the authenticity of the original, or (2) in the circumstances, it is unjust or inequitable to admit the duplicate in lieu of the original.” This provision aligns with modern legal practices and recognizes that duplicates, produced through methods ensuring accuracy, serve the same purpose as originals.

The Court emphasized that a photocopy falls under the definition of a **duplicate** as it is a counterpart produced by the same impression as the original through the action of light. Therefore, unless there is a genuine question about the authenticity of the original or it is unjust to admit the photocopy, it is admissible to the same extent as the original. In Lastimosa’s case, no such questions or allegations were raised, making the photocopy of Vega’s death certificate admissible.

The Court also addressed the defense’s argument that the prosecution failed to present the autopsy report or the testimony of the medico-legal officer. The Court clarified that the submission of an autopsy report or the testimony of the medico-legal officer is not an essential requisite of the crime of Murder. The testimony of Vega’s wife, Dureza, sufficiently established the fact of death as she stated that he had already passed due to gunshot wounds when she arrived at the hospital.

Furthermore, the Court affirmed Lastimosa’s identity as the perpetrator of the crime based on the testimonies of eyewitnesses. Elmer Cañeda and Vicente Cortes both positively identified Lastimosa as the shooter. Cañeda testified that he was only two to three meters away when he saw Lastimosa shoot Vega three times. Cortes corroborated this account, stating that he was about six meters away when he witnessed the shooting. Their testimonies, combined with the death certificate, established Lastimosa’s guilt beyond a reasonable doubt.

The Court then addressed the qualifying circumstance of **treachery**. According to jurisprudence, there is treachery “when the offender commits any of the crimes against the person, employing means, methods, or forms in the execution thereof, which tend directly and specially to ensure its execution, without risk to himself arising from the defense which the offended party might make.” The two elements of treachery are (1) that at the time of the attack, the victim was not in a position to defend himself or herself, and (2) that the offender consciously adopted the particular means, method, or form of attack employed by him or her.

In this case, the Court found that both elements were present. Vega was on his motorcycle when Lastimosa shot him, leaving him unable to defend himself. Lastimosa’s use of a gun and his targeting of Vega’s vital parts demonstrated a conscious effort to ensure the execution of the crime. For these reasons, the Supreme Court affirmed the Court of Appeals’ decision, finding Lastimosa guilty of murder, punishable by reclusion perpetua.

“There is treachery when the offender commits any of the crimes against the person, employing means, methods, or forms in the execution thereof, which tend directly and specially to ensure its execution, without risk to himself arising from the defense which the offended party might make.”

FAQs

What was the key issue in this case?	The key issue was whether a photocopy of a death certificate is admissible as evidence to prove the victim’s death in a murder trial.
What did the Supreme Court rule regarding the admissibility of duplicates?	The Supreme Court ruled that under the 2019 Revised Rules on Evidence, a duplicate, including a photocopy, is admissible to the same extent as the original unless there is a genuine question about the original’s authenticity or it would be unjust to admit the duplicate.
What is the Original Document Rule?	The Original Document Rule, formerly known as the Best Evidence Rule, generally requires that the original document be presented as evidence. However, it now allows for duplicates to be admitted under certain circumstances.
What constitutes a duplicate under the Rules of Evidence?	A duplicate is a counterpart produced by the same impression as the original, or from the same matrix, or by means of photography, including enlargements and miniatures, or by mechanical or electronic re-recording, or by chemical reproduction, or by other equivalent techniques which accurately reproduce the original.
Why was treachery considered a qualifying circumstance in this case?	Treachery was considered a qualifying circumstance because the attack was sudden and unexpected, and the victim was not in a position to defend himself. The accused consciously adopted means to ensure the execution of the crime without risk to himself.
Did the Court consider the lack of an autopsy report problematic for the prosecution’s case?	No, the Court clarified that the submission of an autopsy report or the testimony of the medico-legal officer is not an essential requisite for proving murder. The testimony of the victim’s wife, along with other evidence, was sufficient to establish the fact of death.
What was the significance of the eyewitness testimonies in this case?	The eyewitness testimonies of Elmer Cañeda and Vicente Cortes were crucial in identifying Lastimosa as the perpetrator. Their clear and consistent accounts established that they saw Lastimosa shoot Ildefonso Vega, Jr.
What is the penalty for murder in the Philippines?	The penalty for murder in the Philippines is reclusion perpetua to death, as provided under Article 248 of the Revised Penal Code. In this case, the court imposed the penalty of reclusion perpetua.

This case underscores the importance of understanding the nuances of evidentiary rules in Philippine law. The Supreme Court’s decision provides clarity on the admissibility of duplicate documents, promoting a more efficient and just legal process. It also highlights the critical role of eyewitness testimonies and the qualifying circumstances that elevate a crime to murder.

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. Ybo Lastimosa, G.R. No. 265758, February 03, 2025

February 3, 2025

Chain of Custody in Drug Cases: How a Marking Error Can Lead to Acquittal
Flaws in Evidence Handling: A Broken Chain of Custody Leads to Acquittal in Drug Cases

G.R. No. 250610, July 10, 2023

Imagine being arrested for a crime, only to discover that the evidence against you was mishandled so badly that its integrity is questionable. This is precisely what happened in the case of Francis Valencia and Ryan Antipuesto, where a crucial error in marking evidence led to their acquittal on drug charges. This case underscores the critical importance of following proper procedures in handling evidence, particularly in drug-related offenses, and highlights how even a seemingly minor mistake can have significant legal consequences.

The Importance of Chain of Custody in Drug Cases

In drug cases, the “chain of custody” is a vital legal principle. It refers to the documented and unbroken sequence of possession of evidence, showing who had control over it, from the moment of seizure to its presentation in court. This ensures that the evidence presented is the same evidence seized, without any tampering or alteration. Failure to maintain a proper chain of custody can cast doubt on the authenticity and integrity of the evidence, potentially leading to the acquittal of the accused.

The relevant law governing the handling of drug evidence is Section 21 of Republic Act No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002. This section outlines the procedures that law enforcement officers must follow when seizing and handling dangerous drugs. As amended by Republic Act No. 10640, Section 21 states:

“SECTION 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 [Philippine Drug Enforcement Agency] shall take charge and have custody of all dangerous drugs… for proper disposition in the following manner:
(1) The apprehending team having initial custody and control of the dangerous 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…with an elected public official and a representative of the National Prosecution Service or the media who shall be required to sign the copies of the inventory…”

This provision emphasizes the need for immediate inventory and photographing of the seized items in the presence of specific witnesses. It also allows for exceptions under justifiable grounds, provided the integrity and evidentiary value of the seized items are properly preserved.

The Case of People vs. Valencia and Antipuesto: A Chain Broken

In January 2016, police officers in Dumaguete City conducted a buy-bust operation based on reports of Ryan Antipuesto’s involvement in illegal drug trade. Francis Valencia was with Antipuesto during the operation.
- A police officer, acting as a poseur buyer, purchased a sachet of shabu from Valencia.
- After the transaction, Valencia was arrested, while Antipuesto managed to escape.
- The police officer marked the seized plastic sachet with “FLV/RA-BB-01-16-16.”
- The inventory and photographing of the evidence were conducted at the Dumaguete City Police Station in the presence of Valencia, a barangay chairperson, a media representative, and a representative from the Department of Justice.
However, a critical error occurred when the evidence was submitted to the crime laboratory. The letter requesting the examination initially stated the marking as “FLV/RA-BB-01-16-2016.” This was later altered to “FLV/RA-BB-01-16-16” to match the marking on the sachet. The forensic chemist, Police Officer III Michelle Cañete, allowed the altering of the letter request. This discrepancy in the marking became the focal point of the Supreme Court’s decision.

During the trial, Valencia and Antipuesto presented a different version of events, claiming that Valencia was apprehended without any drugs in his possession, and Antipuesto was simply drinking with a friend at the time of the alleged transaction.

Despite their defense, the trial court found Valencia and Antipuesto guilty beyond reasonable doubt of violating Section 5 of the Comprehensive Dangerous Drugs Act. The Court of Appeals affirmed this decision. However, the Supreme Court reversed the lower courts’ rulings.

The Supreme Court emphasized the importance of maintaining an unbroken chain of custody to ensure the integrity of the evidence. The Court stated, “Receipts showing the chain of custody cannot be altered or modified while the specimen is in transit to the next custodian. Even a minimal change in the marking stated in these documents is fatal to the identity and integrity of the corpus delicti.”

The Court further noted, “While Panggoy was responsible as seizing officer and evidence custodian, he had no authority to modify the Letter Request reflecting the chain of custody. Otherwise, it would be very easy to manipulate the paper trail recording the movement of the corpus delicti.”

Practical Implications of the Ruling

This case serves as a stark reminder of the importance of meticulous evidence handling in drug cases. The Supreme Court’s decision highlights that even a seemingly minor error, such as an alteration in the marking of evidence, can be fatal to the prosecution’s case.

Key Lessons:
- Strict Adherence to Procedures: Law enforcement officers must strictly adhere to the procedures outlined in Section 21 of Republic Act No. 9165 to maintain the integrity of the chain of custody.
- Proper Documentation: Accurate and consistent documentation is crucial. Any discrepancies or alterations in the documentation can cast doubt on the authenticity of the evidence.
- Immediate Marking: Marking of seized items should be done immediately at the place of seizure to avoid any questions regarding the identity of the evidence.
- Investigating Officer: Designate a separate investigating officer who is not involved in the seizure, to avoid conflict of interest.
Hypothetical Example: Imagine a scenario where police officers seize illegal drugs but fail to immediately mark the evidence at the scene. Instead, they wait until they reach the police station, where the marking is done. In court, the defense argues that the delay in marking the evidence creates an opportunity for tampering, and the chain of custody is compromised. Based on the Valencia and Antipuesto ruling, this could lead to the acquittal of the accused.

Frequently Asked Questions

What is the chain of custody in drug cases?

The chain of custody is the documented sequence of possession of evidence, showing who had control over it from the moment of seizure to its presentation in court, ensuring its integrity.

Why is the chain of custody important?

It ensures that the evidence presented in court is the same evidence seized, without any tampering or alteration, maintaining its authenticity and reliability.

What happens if the chain of custody is broken?

If the chain of custody is broken, it can cast doubt on the authenticity and integrity of the evidence, potentially leading to the acquittal of the accused.

What is the role of marking in the chain of custody?

Marking is a crucial step that identifies the corpus delicti, separating the marked illegal drugs from other similar evidence from seizure to disposition.

What should law enforcement officers do if they cannot comply with the requirements of Section 21 of Republic Act No. 9165?

They must acknowledge and justify the deviation and prove that the integrity and evidentiary value of the seized items are properly preserved.

Can a minor error in the chain of custody lead to acquittal?

Yes, even a seemingly minor error, such as an alteration in the marking of evidence, can be fatal to the prosecution’s case.

What is the effect of having a separate investigating officer?

It avoids conflict of interest and ensures that the paper trail recording the movement of the corpus delicti is not easily manipulated.

ASG Law specializes in criminal defense, particularly in drug-related cases. Contact us or email hello@asglawpartners.com to schedule a consultation.
July 10, 2023

Chain of Custody: Safeguarding Drug Evidence Integrity

In the case of People v. David, the Supreme Court acquitted the accused due to critical lapses in the chain of custody of seized drugs, emphasizing the necessity of strict adherence to Section 21 of RA 9165. The Court found that the prosecution failed to provide justifiable reasons for conducting the inventory and taking photographs of the seized drugs at the police station instead of the place of seizure. This ruling underscores the importance of maintaining an unbroken chain of custody to ensure the integrity and admissibility of drug evidence in court, protecting the rights of the accused and preventing potential abuses in drug enforcement operations.

When Pocketing Evidence Undermines Justice: Analyzing Drug Chain of Custody

The case of People of the Philippines vs. Anthony David y Matawaran centers on the integrity of evidence in drug-related cases, specifically addressing the procedural requirements outlined in Section 21 of Republic Act No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002. The accused-appellant, Anthony David y Matawaran, was charged with illegal sale and illegal possession of dangerous drugs. The central issue revolved around whether the prosecution successfully proved his guilt beyond reasonable doubt, particularly in light of alleged lapses in the handling of the seized drugs by the apprehending officers.

The prosecution presented evidence that on August 16, 2015, a confidential informant reported to the police that accused-appellant was engaged in the illegal sale of dangerous drugs. A buy-bust operation was organized, during which PO1 Santos acted as the poseur-buyer and SPO1 Buduan as the backup officer. PO1 Santos testified that he bought a sachet of suspected shabu from accused-appellant using a pre-marked P500.00 bill. After the transaction, accused-appellant was arrested, and another sachet of suspected shabu was allegedly recovered from him during a body search.

However, critical issues arose regarding the handling of the seized items. PO1 Santos admitted to placing the seized sachets in his pockets before marking them, raising concerns about potential tampering or switching of evidence. The inventory and taking of photographs of the seized items were conducted at the police station, not at the place of seizure, and no justifiable reason was provided for this deviation from the standard procedure. These procedural lapses became central to the Supreme Court’s analysis.

The Supreme Court emphasized the importance of the chain of custody in drug cases, noting that the drug itself constitutes the corpus delicti. It stated that the prosecution must establish that the substance illegally sold and possessed by the accused is the same substance presented in court. The chain of custody rule ensures that unnecessary doubts concerning the identity of the evidence are removed. Section 21 of RA 9165, as amended by RA 10640, outlines the procedures for the custody and disposition of confiscated drugs. The provision requires that the apprehending team conduct a physical inventory and photograph the seized items immediately after seizure and confiscation, in the presence of the accused or his representative, an elected public official, and a representative from the National Prosecution Service or the media.

The Court highlighted that for warrantless seizures, the inventory and taking of photographs should be done at the place of seizure, or in the nearest police station or office of the apprehending team, whichever is practicable. The operative phrase is “whichever is practicable,” meaning the police officers have the option to conduct the process in the nearest police station, provided that it is not practicable to conduct the process at the place of seizure, or the items seized are threatened by immediate or extreme danger at the place of seizure.

In this case, the Court found that the police officers did not provide any justifiable reason to excuse them from conducting the inventory and taking of photographs of the seized illegal drugs in the place of seizure. This lack of explanation was deemed fatal to the prosecution’s case. The Court cited the case of People v. Casa, where it was stressed that the conduct of inventory and the taking of photographs of seized items must generally be accomplished immediately at the place of arrest or seizure. Deviations from this general rule are justified only in specific instances, such as when law enforcers would be placed in dangerous situations, or where the seized items or any person involved in the operation are threatened by immediate or extreme danger at the place of seizure.

Building on this principle, the Court noted that the prosecution failed to establish beyond reasonable doubt that the illegal drugs presented in court were the same illegal drugs that were actually seized from accused-appellant. PO1 Santos immediately placed the seized plastic sachets in his pockets even before they were marked. The Court has previously ruled that keeping the seized items in the pockets is a doubtful and suspicious way of ensuring the integrity of the items. In People v. Asaytuno, the Court emphasized the dangers of a police officer bodily-keeping the confiscated items, stating that it is fraught with dangers. The failure to mark the drugs immediately after they were seized from the accused casts doubt on the prosecution evidence warranting an acquittal on reasonable doubt.

Furthermore, the prosecution failed to account for the transfer of the seized illegal drugs from the apprehending officer to the investigating officer. PO1 Santos testified that he was the one who brought the two plastic sachets of suspected shabu to the crime laboratory for examination, as evidenced by the Chain of Custody Receipt. There was no turnover made by the seizing or arresting officer to the investigating officer, which casts doubt on the integrity of the seized items.

Additionally, the turnover and submission of the marked illegal drugs from the forensic chemist to the court were not sufficiently shown. The parties entered into general stipulations on the forensic chemist’s testimony, but these stipulations were incomplete and did not establish that the seized items’ integrity and evidentiary value were preserved. The stipulation did not mention the condition of the specimens when the forensic chemist received them, the description of the method utilized in analyzing the chemical composition of the drug samples, whether she resealed the specimens after examination, or the manner of handling and storage of the specimens before, during, and after the chemical examination.

The Court concluded that the prosecution’s failure to establish with moral certainty the identity and the unbroken chain of custody of the dangerous drugs allegedly seized from accused-appellant created reasonable doubt as to whether these illegal drugs were the same drugs presented in court. This compromised the identity, integrity, and evidentiary value of the corpus delicti of the offenses charged. As a result, the Court acquitted accused-appellant Anthony David y Matawaran of violation of Sections 5 and 11, Article II of Republic Act No. 9165.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution sufficiently proved the guilt of the accused beyond reasonable doubt for illegal sale and possession of dangerous drugs, considering alleged lapses in the chain of custody of the seized drugs.
What is the chain of custody rule?	The chain of custody rule requires that the prosecution account for each link in the chain, from the moment the item was picked up to the time it is offered into evidence, ensuring that the integrity and identity of the evidence are preserved.
What does Section 21 of RA 9165 require?	Section 21 requires the apprehending team to conduct a physical inventory and photograph the seized items immediately after seizure and confiscation, in the presence of the accused, an elected public official, and a representative from the National Prosecution Service or the media.
Why was the inventory not done at the place of seizure?	The police officers conducted the inventory and took photographs at the police station instead of the place of seizure. The court found that the police officers failed to provide any justifiable reason for this deviation from the required procedure.
What was the significance of PO1 Santos placing the seized items in his pockets?	PO1 Santos’s act of placing the seized items in his pockets before marking them raised concerns about potential tampering or switching of evidence, undermining the integrity of the chain of custody.
Why was the incomplete stipulation of the forensic chemist’s testimony a problem?	The incomplete stipulation failed to establish that the integrity and evidentiary value of the seized items were preserved during the forensic examination, creating doubts about whether the drugs presented in court were the same ones seized from the accused.
What is the role of an investigating officer?	The investigating officer is responsible for conducting the proper investigation and preparing the necessary documents for developing the criminal case, requiring them to have possession of the illegal drugs for the preparation of the required documents.
What is the effect of not following the chain of custody rule?	Failure to comply with the chain of custody rule creates reasonable doubt as to whether the illegal drugs presented in court were the same drugs seized from the accused, potentially leading to acquittal.

This case serves as a stern reminder to law enforcement agencies about the critical importance of adhering to established procedures in handling drug evidence. The strict requirements of Section 21 of RA 9165 are designed to safeguard the integrity of the evidence and protect the rights of the accused. Failure to comply with these requirements can have significant consequences, including the dismissal of charges and the release of individuals accused of 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.

June 21, 2023

Drug Den Conviction Overturned: Isolated Incidents and Chain of Custody Failures

The Supreme Court acquitted Bobby Lopina of maintaining a drug den, overturning the lower courts’ conviction. The Court emphasized that a single, isolated drug transaction does not establish a pattern of regular drug use or sales required to prove the existence of a drug den. Furthermore, the prosecution’s failure to establish an unbroken chain of custody for the seized evidence compromised the integrity of the corpus delicti, leading to the acquittal. This decision underscores the stringent evidentiary standards required for drug den convictions and the critical importance of adhering to chain of custody procedures.

From Pigpen to Prison? Scrutinizing Evidence in Drug Den Cases

This case revolves around Bobby Lopina, who was convicted of maintaining a drug den based on a test-buy and items found during a search of his residence. The central legal question is whether the prosecution presented sufficient evidence to prove beyond a reasonable doubt that Lopina maintained a place where dangerous drugs were regularly used, sold, or stored.

To secure a conviction for maintaining a drug den under Section 6 of Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002, the prosecution must prove two key elements beyond a reasonable doubt. First, they must establish that the place in question is indeed a den, meaning a location where dangerous drugs are administered, used, sold, or stored for illegal purposes. Second, the prosecution must prove that the accused actively maintained the said place as a drug den. The absence of sufficient evidence to prove both elements can lead to an acquittal, as highlighted in this case.

In this case, the evidence presented by the prosecution relied heavily on two key points: the alleged test-buy conducted by PDEA agents four days prior to the search warrant implementation, and the drug paraphernalia and plastic sachets containing shabu purportedly found inside Lopina’s house. However, the Supreme Court found these pieces of evidence insufficient to establish beyond a reasonable doubt that Lopina was maintaining a drug den. The Court referenced the case of People v. Andanar and Garbo, where the Court acquitted Mary Jane Garbo due to the prosecution’s failure to prove that her house was used as a place where dangerous drugs were regularly sold or used.

First, a drug den is a lair or hideaway where prohibited or regulated drugs are used in any form or are found. Its existence may be proved not only by direct evidence but may also be established by proof of facts and circumstances, including evidence of the general reputation of the house, or its general reputation among police officers.

The Supreme Court emphasized that the prosecution must establish that the alleged drug den is a place where dangerous drugs are regularly sold to or used by customers. The term “regular” implies a consistent pattern or common occurrence, not just an isolated incident. In Lopina’s case, the single test-buy was deemed insufficient to demonstrate that his house was frequently used for illegal drug transactions. The Court noted that there was no evidence presented to show that Lopina’s house had a general reputation as a drug den or that it was regularly used as a hideaway for drug-related activities. Therefore, the evidence failed to meet the threshold required to convict him of maintaining a drug den.

Further undermining the prosecution’s case was the fact that when the PDEA team served the search warrant, Lopina and the other occupants of the house were not actively engaged in any criminal activity related to drug use, sale, or storage. In fact, Lopina was in his backyard cleaning the pigpen when he was apprehended by a PDEA agent. This detail raised further doubts about whether the house was indeed being used as a drug den at the time of the search. These circumstances led the Supreme Court to conclude that Lopina could not be considered a maintainer of a drug den based on the evidence presented.

Even more critical to the Supreme Court’s decision was the significant violation of the chain of custody rule. The chain of custody rule, outlined in Section 21 of RA 9165 as amended by RA 10640, is crucial in drug-related cases to ensure the integrity and identity of the seized narcotic substance. This rule applies whether the drugs were seized in a buy-bust operation or through a search warrant. The corpus delicti, or the body of the crime, in drug cases is the seized narcotic substance itself. Therefore, it is essential to maintain an unbroken chain of custody from the moment the drugs are seized until they are presented in court as evidence.

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;

To establish an unbroken chain of custody, the prosecution must present testimony about every link in the chain, from the moment the item was seized to the time it is offered in court as evidence. The required links include the seizure and marking of the illegal drug, the turnover of the drug to the investigating officer, the turnover by the investigating officer to the forensic chemist, and finally, the turnover and submission of the drug from the forensic chemist to the court. Any break or gap in this chain can raise doubts about the integrity of the evidence and potentially lead to an acquittal.

In this case, the searching team failed to fully comply with the chain of custody rule. Crucially, no chain-of-custody form was accomplished by the PDEA agents. This meant that there was no documentary evidence of every link in the chain, from the moment the items were seized to the time they were offered as evidence in court. The absence of this documentation made it difficult to verify the integrity and identity of the seized items. Furthermore, the PDEA agents failed to comply with the second and fourth links in the chain of custody: the turnover of the illegal drugs to the investigating officer and the turnover and submission of the drugs from the forensic chemist to the court. Records showed that while IOI Sabanal turned over the seized items to IO1 Panaguiton, the evidence custodian, they were not turned over to an investigator. Additionally, there was no information provided on how the seized items were submitted by the forensic chemist to the court for identification. These gaps in the chain of custody created significant doubts about the integrity of the seized illegal drugs.

The Court reiterated that the chain of custody requirement under Section 21 of RA 9165 is a matter of substantive law and cannot be brushed aside as a simple procedural technicality. The law was designed to safeguard against potential police abuses, especially considering the severe penalties involved in drug-related offenses. The Court emphasized that failure to prove the integrity of the corpus delicti renders the evidence for the State insufficient to prove the guilt of the accused-appellant, warranting his acquittal. Because the prosecution failed to establish beyond a reasonable doubt that Lopina was maintaining a drug den and failed to maintain a proper chain of custody, the Supreme Court granted the appeal and acquitted him of the charge.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution presented sufficient evidence to prove beyond a reasonable doubt that Bobby Lopina maintained a drug den in violation of Section 6 of RA 9165, and whether the chain of custody of the seized drugs was properly maintained.
What is required to prove the existence of a drug den?	To prove the existence of a drug den, the prosecution must show that the place is a lair or hideaway where prohibited drugs are regularly used or sold, not just an isolated incident. Evidence of the general reputation of the house can also be considered.
Why was the test-buy evidence insufficient in this case?	The test-buy was considered insufficient because it only proved an isolated illegal drug transaction and did not establish that Lopina’s house was frequently used as a drug den or had a general reputation as such.
What is the chain of custody rule?	The chain of custody rule requires the prosecution to account for each link in the chain from the moment the drugs are seized to their presentation in court. This ensures the integrity and identity of the evidence.
What are the key links in the chain of custody?	The key links include the seizure and marking of the illegal drug, the turnover to the investigating officer, the turnover to the forensic chemist, and the submission of the drug to the court.
What happened to the chain of custody in this case?	The chain of custody was broken because no chain-of-custody form was accomplished, and there were gaps in the turnover of the drugs to the investigating officer and the submission of the drugs to the court.
Why is the chain of custody rule so important?	The chain of custody rule is a matter of substantive law designed to prevent police abuses and ensure the integrity of the evidence, especially given the severe penalties in drug-related offenses.
What was the outcome of the case?	The Supreme Court granted the appeal and acquitted Bobby Lopina of the charge of maintaining a drug den due to insufficient evidence and a broken chain of custody.

The Supreme Court’s decision in this case serves as a reminder of the high burden of proof required to convict individuals of drug-related offenses. It highlights the importance of establishing a clear pattern of drug-related activity to prove the existence of a drug den and the necessity of strictly adhering to the chain of custody rule to ensure the integrity of the evidence presented in court.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

February 22, 2023

Chain of Custody: Safeguarding Rights in Drug Cases Despite Quantity

In a significant ruling, the Supreme Court acquitted Robert Uy of drug-related charges, emphasizing the mandatory compliance with the chain of custody rule, irrespective of the quantity of drugs involved; failure to adhere to this procedure introduces reasonable doubt. This decision underscores the importance of strict adherence to legal protocols in drug cases to protect individual rights. It serves as a stern reminder to law enforcement and the prosecution to meticulously follow the prescribed procedures for handling evidence, ensuring the integrity of the legal process. The acquittal highlights that procedural shortcuts are unacceptable, even when substantial quantities of narcotics are at stake, reinforcing the judiciary’s commitment to due process and fair trial.

When Procedural Lapses Undermine Drug Convictions: A Case of Reasonable Doubt

The case of People of the Philippines vs. Robert Uy y Ting revolves around Robert Uy’s conviction for violations of Republic Act (R.A.) No. 9165, specifically Sections 5 and 11, concerning the transportation and possession of dangerous drugs. The charges stemmed from two incidents: one involving nearly 10 kilograms of shabu and another related to a warehouse containing over 230 kilograms of the same substance. The Supreme Court, however, overturned his conviction, citing critical failures in adhering to the mandatory chain of custody requirements outlined in Section 21 of R.A. No. 9165.

The legal framework at the heart of this case is Section 21 of R.A. No. 9165, which mandates a strict protocol for the handling of seized drugs. This protocol includes immediate inventory, photographing the drugs in the presence of the accused, and representatives from the media, the Department of Justice (DOJ), and any elected public official. This safeguards against contamination, tampering, or substitution of the evidence is aimed at preserving the integrity of the evidence throughout the legal proceedings. The chain of custody requirement is a detailed process aimed at maintaining the integrity and identity of the seized drugs from the moment of confiscation to its presentation in court.

The Supreme Court identified several critical lapses in the procedures followed by law enforcement. There was a lack of proper documentation, the absence of required witnesses during key stages of evidence handling, and inconsistencies in the handling of the seized items. Specifically, the inventory and photography of the drugs were not conducted in the presence of all the mandated witnesses. Moreover, the prosecution failed to provide justifiable reasons for these procedural lapses, nor did they adequately demonstrate that the integrity and evidentiary value of the seized items were preserved. These failures, the Court reasoned, created a reasonable doubt regarding the identity and integrity of the corpus delicti, which is the body of the crime itself, necessitating Uy’s acquittal.

The Court emphasized that the stringent requirements of Section 21 of R.A. No. 9165 are mandatory, regardless of the quantity of drugs involved. It rejected the notion that the large volume of drugs could excuse non-compliance with the procedural safeguards. The Court’s reasoning is anchored in the constitutional right of the accused to due process, which guarantees that every individual is presumed innocent until proven guilty beyond a reasonable doubt. In this case, the procedural lapses introduced uncertainty about the evidence’s integrity, undermining the prosecution’s case and warranting an acquittal. The Supreme Court, in this case, reinforced the idea that the failure to establish every link in the chain of custody undermines the integrity of the evidence.

Further, the Supreme Court extended the acquittal to Willie Gan, Uy’s co-accused, despite Gan not appealing his conviction. This decision was based on Section 11, Rule 122 of the Revised Rules of Criminal Procedure, which stipulates that an appellate court’s favorable judgment should also benefit non-appealing co-accused when applicable. The Court found that the defects in the chain of custody applied equally to Uy and Gan, justifying the extension of the acquittal. This demonstrates the Court’s commitment to fairness and consistency in the application of the law.

This case underscores the critical importance of adhering to the procedural safeguards in drug cases. It serves as a warning to law enforcement agencies and the prosecution to meticulously comply with the requirements of Section 21 of R.A. No. 9165. The decision makes clear that any lapses in the chain of custody, no matter how seemingly minor, can undermine the prosecution’s case and lead to the acquittal of the accused. It also highlights the Court’s willingness to apply these safeguards rigorously, even when large quantities of drugs are involved. In conclusion, the Supreme Court’s decision in People vs. Robert Uy reinforces the importance of procedural compliance in drug cases, even when substantial quantities of narcotics are involved. It serves as a reminder that the rights of the accused and the integrity of the legal process must always be paramount.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution adequately established the chain of custody for the seized drugs, as required by Section 21 of R.A. No. 9165, to prove the integrity and identity of the evidence. The Supreme Court found critical lapses in this procedure, leading to the acquittal of the accused.
What is the chain of custody rule in drug cases?	The chain of custody rule refers to the documented and authorized transfer of seized drugs from the point of confiscation to presentation in court. It involves a detailed record of who handled the evidence, when, and what changes occurred, ensuring the integrity and identity of the drugs.
Why is the chain of custody rule important?	It is important because it safeguards against the contamination, tampering, or substitution of evidence. This is especially critical in drug cases where the seized substance is the primary evidence, and its integrity must be maintained to ensure a fair trial.
What are the required steps in the chain of custody?	The required steps include seizure and marking, turnover to the investigating officer, transmittal to the forensic chemist, and submission of the marked illegal drugs from the forensic chemist to the court. Each step must be properly documented and accounted for.
Who are the required witnesses during the inventory of seized drugs?	The law requires the presence of the accused (or their representative), a media representative, a representative from the Department of Justice (DOJ), and any elected public official during the inventory and photographing of seized drugs. Their presence ensures transparency and prevents abuse.
What happens if the chain of custody is broken?	If the chain of custody is broken, it creates reasonable doubt about the integrity and identity of the evidence. This may result in the acquittal of the accused, as the prosecution cannot prove the corpus delicti or body of the crime beyond a reasonable doubt.
Does the quantity of drugs affect the chain of custody rule?	The Supreme Court clarified that the chain of custody rule applies regardless of the quantity of drugs involved. While the potential for tampering may be lower with larger quantities, the procedural safeguards remain essential to ensure due process.
What is the effect of this ruling on future drug cases?	This ruling serves as a reminder to law enforcement and the prosecution to meticulously comply with the requirements of Section 21 of R.A. No. 9165. Failure to do so can undermine their case and lead to the acquittal of the accused.
How did this ruling affect the co-accused in this case?	The Supreme Court extended the acquittal to Willie Gan, Uy’s co-accused, even though Gan did not appeal his conviction. This was based on the principle that an appellate court’s favorable judgment should also benefit non-appealing co-accused when applicable.

The Supreme Court’s decision emphasizes that the pursuit of justice requires strict adherence to legal procedures, safeguarding individual rights against potential abuse. It serves as a lesson to law enforcement agencies and the prosecution, emphasizing the importance of procedural compliance in drug cases.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

February 21, 2023

Parricide Conviction Upheld: Extrajudicial Confessions and Circumstantial Evidence in Family Violence Cases

The Supreme Court affirmed the conviction of Diane Argayan for parricide, emphasizing that while direct evidence isn’t mandatory, a combination of circumstantial evidence and a voluntary extrajudicial confession can establish guilt beyond reasonable doubt. This decision underscores that even without eyewitness testimony, the totality of evidence, including admissions made outside of custodial interrogation and proven circumstances, can lead to a parricide conviction. It reinforces the importance of extrajudicial statements and circumstantial evidence in prosecuting domestic violence cases, providing a legal pathway for justice when direct evidence is scarce.

A Mother’s Silence: Can Uncounseled Confessions and Circumstantial Clues Seal a Parricide Case?

This case revolves around the tragic death of Jeana Rose Argayan Mangili, a three-year-old, who was found dead with multiple stab and hack wounds. Her mother, Diane Argayan, was charged with parricide. The prosecution’s case hinged on the testimony of a six-year-old witness, Raven Rhyzl Cha-ong, along with circumstantial evidence and an alleged extrajudicial confession by Diane. Diane chose not to present any evidence in her defense, leading the trial court to convict her, a decision affirmed by the Court of Appeals (CA). This appeal to the Supreme Court questions whether the CA erred in upholding Diane’s conviction based on the evidence presented.

At the heart of this case is the interpretation and admissibility of Diane’s statements to a social worker, Girlie O. Willie. The court grappled with whether Diane’s admission constituted a valid extrajudicial confession, given it was not made during custodial investigation nor with legal counsel present. The Constitution guarantees rights to individuals under custodial investigation, as highlighted in Section 12, Article III:

Section 12. (1) Any person under investigation for the commission of an offense shall have the right to be informed of his right to remain silent and to have competent and independent counsel preferably of his own choice.

The Court emphasized that these protections primarily aim to prevent coerced confessions during formal questioning by law enforcement. However, the circumstances of Diane’s admission were distinct; it was a voluntary disclosure made to a social worker providing support, not during a police interrogation. Therefore, these safeguards do not apply in situations where statements are made freely and without coercion.

Building on this principle, the Supreme Court referenced the case of People v. Andan, where a confession made to a mayor was deemed admissible because it was volunteered, not elicited through interrogation. The Court differentiated between confessions obtained through custodial interrogation and spontaneous admissions made in confidence. This distinction is crucial because it highlights that not all incriminating statements require the stringent protections afforded during police questioning.

Furthermore, the court clarified that for an extrajudicial confession to warrant conviction, it must be corroborated by evidence of the corpus delicti, meaning the fact that a crime was committed. Section 3, Rule 133 of the Rules of Court stipulates:

Sec. 3. Extrajudicial confession, not sufficient ground for conviction. — An extrajudicial confession made by an accused, shall not be sufficient ground for conviction, unless corroborated by evidence of corpus delicti.

The Court asserted that the prosecution successfully established the corpus delicti through Jeana’s death certificate, medico-legal reports, and testimonial evidence, thereby validating Diane’s confession as credible evidence. It means that it should be proved that first, certain facts have been proven—say, a person has died or a building has been burned; and second, a particular person is criminally responsible for the act

The Court also considered the role of circumstantial evidence. Even without direct eyewitness testimony, the prosecution presented a chain of circumstances pointing to Diane’s guilt. These included: (1) Diane, Raven, and Jeana were the only ones present; (2) Jeana was left alone with Diane before being discovered injured; (3) Jeana identified her mother as her attacker; (4) Diane’s ambiguous response to the accusation; (5) Diane’s subsequent actions, such as cleaning the scene; and (6) blood on Diane’s feet.

The requisites for conviction based on circumstantial evidence, as outlined in Section 4, Rule 133 of the Rules of Court, include:

(a) There is more than one circumstance;

(b) The facts from which the inferences are derived are proven; and

(c) The combination of all the circumstances is such as to produce a conviction beyond reasonable doubt.

The court stated that all these requisites are present in the instant case and that it could uphold the decision of the lower courts. Building on these points, the Court emphasized that Raven’s testimony was deemed credible by both the RTC and CA. This credibility is crucial because the Court defers to the trial court’s assessment of witness demeanor and truthfulness unless there is a clear error. The consistent findings regarding Raven’s credibility strengthened the circumstantial case against Diane, illustrating the importance of a witness’s believability in the absence of direct evidence.

In summary, the Supreme Court highlighted that while an uncounseled confession alone cannot secure a conviction, it becomes compelling when coupled with corroborating evidence and convincing circumstantial proof. This approach contrasts with cases where confessions are coerced or obtained during custodial interrogation without proper safeguards. In those instances, such confessions are inadmissible, underscoring the stringent protections afforded to individuals undergoing police questioning.

This approach contrasts with cases where confessions are coerced or obtained during custodial interrogation without proper safeguards. In those instances, such confessions are inadmissible, underscoring the stringent protections afforded to individuals undergoing police questioning. The Court’s decision not only upheld the conviction but also affirmed the legal framework for assessing evidence in parricide cases, particularly where direct evidence is lacking.

Consequently, Diane was sentenced to reclusion perpetua and ordered to pay civil indemnity, moral damages, exemplary damages, and temperate damages to the heirs of the victim. The Court also modified the award by granting temperate damages. This highlights the gravity of the crime of parricide and the legal repercussions for those found guilty.

FAQs

What is parricide under Philippine law?	Parricide is the act of killing one’s father, mother, child (legitimate or illegitimate), ascendant, descendant, or spouse. It is defined and penalized under Article 246 of the Revised Penal Code, carrying a penalty of reclusion perpetua to death.
What is the significance of an extrajudicial confession in a parricide case?	An extrajudicial confession can be a critical piece of evidence, but it must be voluntary and corroborated by evidence of the corpus delicti, which is the fact that a crime was committed. The confession cannot be the sole basis for conviction without such corroboration.
What are the requirements for circumstantial evidence to lead to a conviction?	Circumstantial evidence is sufficient for conviction if there is more than one circumstance, the facts from which the inferences are derived are proven, and the combination of all circumstances produces a conviction beyond reasonable doubt. The circumstances must form an unbroken chain leading to the conclusion that the accused committed the crime.
*What does corpus delicti* mean in legal terms?**	Corpus delicti refers to the body, foundation, or substance of a crime. It involves proving that a certain act occurred (e.g., a death) and that someone is criminally responsible for that act.
Can a person be convicted of parricide without direct evidence?	Yes, a person can be convicted of parricide based on circumstantial evidence, provided that the evidence meets the standards of sufficiency and leads to the reasonable conclusion that the accused is guilty beyond a reasonable doubt. It needs corroborating evidence with confession.
What are the rights of a person under custodial investigation?	Under Section 12, Article III of the Constitution, a person under custodial investigation has the right to remain silent, to have competent and independent counsel (preferably of their own choice), and to be informed of these rights. Any waiver of these rights must be in writing and in the presence of counsel.
What is the penalty for parricide in the Philippines?	The penalty for parricide is reclusion perpetua to death, as defined under Article 246 of the Revised Penal Code. The specific penalty imposed depends on the presence of any mitigating or aggravating circumstances.
What types of damages can be awarded in a parricide case?	In a parricide case, the court may award civil indemnity, moral damages, exemplary damages, and temperate damages to the heirs of the victim. Civil indemnity is compensation for the loss suffered, moral damages are for the emotional distress, exemplary damages serve as a deterrent, and temperate damages are awarded when pecuniary loss is proven but the exact amount is not.

In conclusion, the Supreme Court’s decision in People v. Diane Argayan emphasizes the weight given to circumstantial evidence and voluntary extrajudicial confessions in parricide cases. It underscores the importance of presenting a strong, cohesive case, even in the absence of direct evidence, to ensure justice for victims of domestic violence.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

January 30, 2023

Custody Chain Integrity: Safeguarding Drug Evidence in Philippine Law

In People v. Tamundi, the Supreme Court affirmed the conviction of Nadjera Tamundi for illegal drug sale, emphasizing the critical importance of maintaining the chain of custody for seized drugs. The Court clarified that while strict adherence to procedural requirements is essential, justifiable deviations, such as a witness’s refusal to sign inventory receipts due to company policy, do not automatically invalidate the evidence if the integrity and evidentiary value of the seized drugs are preserved. This decision underscores the balance between procedural compliance and the overarching goal of ensuring justice in drug-related cases.

When a Witness Won’t Sign: Upholding Drug Convictions Despite Procedural Hiccups

This case revolves around Nadjera Tamundi’s arrest and conviction for selling 295.53 grams of methamphetamine hydrochloride, commonly known as shabu, during a buy-bust operation. The prosecution presented evidence that Tamundi sold the drugs to an undercover police officer, PO3 Junel Dela Cruz, in exchange for P300,000.00, consisting of marked money and boodle money. After the exchange, Tamundi was arrested by SPO2 Michael Calimlim, and an inventory of the seized items was conducted at the scene. This inventory was witnessed by Rod Vega, a media representative from DZBB, and Barangay Kagawad Pedro B. Battung, Jr. However, Vega refused to sign the inventory receipt, citing company policy. The central legal question is whether this deviation from the standard procedure compromised the integrity of the evidence and warranted the overturning of Tamundi’s conviction.

The Regional Trial Court (RTC) found Tamundi guilty, a decision affirmed by the Court of Appeals (CA). Both courts emphasized the positive identification of Tamundi as the seller and the unbroken chain of custody of the confiscated shabu. The Supreme Court (SC) agreed, highlighting the essential elements for a conviction under Section 5, Article II of Republic Act No. 9165 (RA 9165), the “Comprehensive Dangerous Drugs Act of 2002”. These elements include the identification of the buyer and seller, the object of the sale, the consideration, and the delivery of the thing sold along with the payment. Crucially, the Court reiterated the need for proof that the sale actually took place, supported by evidence of the corpus delicti, which in drug cases, is the seized dangerous drugs.

The defense challenged the integrity of the chain of custody, particularly focusing on the media representative’s refusal to sign the inventory receipt. The SC acknowledged the importance of following the chain of custody procedure but also recognized that justifiable deviations could occur. Section 21 of RA 9165 outlines the procedure for handling seized drugs, including the requirement for an inventory and photography of the drugs in the presence of the accused, an elected public official, and representatives from the DOJ or the media. The 2014 amendment to RA 9165, through RA 10640, streamlined this requirement to include only two witnesses: an elected public official and a DOJ or media representative. The Court emphasized that the prosecution must plead and prove any justifiable grounds for deviation from these requirements, demonstrating that the integrity and evidentiary value of the seized drugs were preserved.

In this case, the Court found that the police officers had made reasonable efforts to comply with the requirements of Section 21. They secured the presence of both a media representative and a barangay official as witnesses. The police also attempted to contact a representative from the DOJ, but no one was available at the time of the operation. Although the media representative, Vega, refused to sign the inventory receipt, his presence during the inventory and photography was established through the testimony of the police officers and the inventory receipts themselves, which noted Vega’s refusal to sign. The Court accepted the explanation that Vega’s refusal was based on company policy, deeming this a justifiable reason for the deviation from the strict requirements of the law.

The Supreme Court referenced prior jurisprudence on the chain of custody, noting that the procedure is not merely a procedural technicality but a matter of substantive law. However, the Court also recognized that strict compliance is not always possible and that the focus should be on preserving the integrity and evidentiary value of the seized drugs. The links in the chain of custody that must be established are: first, the seizure and marking of the illegal drug recovered from the accused; second, the turnover of the illegal drug to the investigating officer; third, the turnover by the investigating officer to the forensic chemist for examination; and fourth, the turnover and submission of the marked illegal drug from the forensic chemist to the court. These links were proven in this case through the testimonies of the police officers, the forensic chemist, and the evidence custodian, as well as the documentary evidence presented.

The Court analyzed the specific facts of the case to determine whether the integrity of the evidence had been compromised. PO3 Dela Cruz marked the black Guess paper bag and the plastic bag containing the confiscated shabu immediately after Tamundi’s arrest. An inventory was made, and photographs were taken at the place of arrest in the presence of Vega and Barangay Kagawad Battung, Jr. The confiscated shabu remained in PO3 Dela Cruz’s possession as they returned to the police station, where it was then turned over to PO3 Peña for laboratory examination. PCI De Guzman conducted the examination, confirming the substance as methamphetamine hydrochloride, and then turned the evidence over to PO2 Castillo for safekeeping until it was presented in court. The Court concluded that these circumstances sufficiently justified the slight deviation from the requirements under Section 21 of RA 9165, emphasizing that the police officers had intended to comply with the law but were thwarted by Vega’s refusal to sign.

The Supreme Court emphasized that the prosecution had successfully proven all elements of the illegal sale of dangerous drugs, including the identity of the buyer and seller, the object of the sale, the consideration, and the actual exchange of the drugs for money. Despite the absence of the marked money in court, its presence during the buy-bust operation was sufficiently established through the testimonies of the police officers and the positive result of the UV powder test. Moreover, the Court gave weight to the testimonies of the police officers, who enjoy the presumption of regularity in the performance of their duties.

The Court contrasted the positive testimonies of the prosecution witnesses with the defense offered by Tamundi, which consisted of a denial of the allegations. The RTC had found Tamundi’s denial unavailing, noting that she had failed to present any corroborating witnesses to support her claims. The Supreme Court affirmed this finding, reiterating the principle that positive identification prevails over a mere denial. As such, the high court found no reason to overturn the lower courts’ decisions.

FAQs

What was the key issue in this case?	The key issue was whether the conviction for illegal drug sale could stand despite the media representative’s refusal to sign the inventory receipt, a deviation from the standard chain of custody procedure.
What is the chain of custody rule?	The chain of custody rule requires that the prosecution account for the custody of seized drugs from the moment of seizure to its presentation in court as evidence, ensuring its integrity and preventing substitution.
What are the required witnesses during the inventory of seized drugs?	As amended by RA 10640, the inventory and photography of seized drugs must be done in the presence of an elected public official and a representative from the DOJ or the media.
What happens if there is a deviation from the chain of custody rule?	The prosecution must provide a justifiable reason for the deviation and demonstrate that the integrity and evidentiary value of the seized drugs were preserved despite the deviation.
What was the justifiable reason in this case?	The justifiable reason was the media representative’s refusal to sign the inventory receipt due to company policy, which the Court found acceptable under the circumstances.
Why was the marked money not presented in court?	Although the marked money was not presented in court, its presence during the buy-bust operation was sufficiently established through the testimonies of the police officers and the UV powder test results.
*What is the significance of the corpus delicti* in drug cases?**	The corpus delicti, or body of the crime, in drug cases is the seized dangerous drugs themselves, which must be proven to be the same substance involved in the illegal transaction.
What is the effect of the presumption of regularity in the performance of duties?	The presumption of regularity means that law enforcement officers are presumed to have acted in accordance with the law, unless there is evidence to the contrary.
What was the penalty imposed on Nadjera Tamundi?	Nadjera Tamundi was sentenced to life imprisonment and ordered to pay a fine of Five Hundred Thousand Pesos (P500,000.00).

In conclusion, People v. Tamundi serves as a reminder of the complexities involved in drug-related cases and the importance of balancing procedural requirements with the pursuit of justice. While strict compliance with the chain of custody rule is ideal, justifiable deviations will not automatically invalidate a conviction if the integrity and evidentiary value of the seized drugs are preserved. This ruling highlights the need for law enforcement officers to exercise diligence and good faith in handling drug evidence, even in challenging circumstances.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

December 7, 2022

Buy-Bust Operations: Ensuring Integrity in Drug Evidence and Upholding Chain of Custody

In the case of People of the Philippines v. Jose Vastine y Gibson, the Supreme Court affirmed the conviction of the accused for illegal sale and use of dangerous drugs, emphasizing the importance of upholding the integrity of drug evidence while recognizing justifiable deviations from the standard chain of custody. This decision underscores the necessity of proving the transaction and presenting the illicit drug as evidence, while also acknowledging the practical challenges faced by law enforcement in adhering strictly to procedural requirements. The ruling clarifies the balance between enforcing drug laws and protecting individual liberties, particularly in the context of buy-bust operations.

Did Police Secure Drug Evidence Properly?: Examining Buy-Bust Protocol in Vastine Case

The narrative begins with a confidential informant tipping off the Anti-Illegal Drug Special Operation Task Force (AIDSOTF) about Jose Vastine’s drug trade activities. This led to a buy-bust operation where PO3 Mabanglo acted as the poseur buyer, agreeing to purchase two kilos of cocaine for P800,000.00. The operation unfolded at the Market! Market! Mall in Taguig, where Vastine, along with Albert Ong and Edilberto Ty, were apprehended after the exchange of money and drugs. Following the arrest, the seized drugs were marked, inventoried, and sent to the crime laboratory for examination, revealing that the substances tested positive for cocaine, and Vastine tested positive for marijuana use. The trial court found Vastine, Ong, and Ty guilty, but the Court of Appeals later acquitted Ong and Ty of illegal drug sale, while sustaining Vastine’s conviction.

The central legal question revolves around whether the prosecution successfully proved Vastine’s guilt beyond reasonable doubt for both illegal sale and illegal use of dangerous drugs. For illegal sale, the prosecution needed to establish that the transaction occurred and present the corpus delicti, or the illicit drug, as evidence. Crucially, proving a sale requires showing the identities of the buyer and seller, the object of the sale, the consideration, and the delivery of the item with payment. In Vastine’s case, the prosecution demonstrated that PO3 Mabanglo purchased cocaine from Vastine during a buy-bust operation, with the exchange of money and drugs clearly establishing the transaction.

Accused-appellant’s defense argued the police officers failed to comply with Sec. 21, Art. II of RA 9165, specifically as to their failure to adduce a justifiable reason for the absence of a representative from the DOJ. To address the illegal use charge, the prosecution relied on the initial and confirmatory tests conducted by PCI Julian, which confirmed the presence of marijuana in Vastine’s system. This evidence was critical in upholding Vastine’s conviction under Sec. 15, Art. II of RA 9165.

A significant aspect of this case is the chain of custody of the seized drugs, which is essential for preserving the integrity and evidentiary value of the evidence. Section 21, Art. II of RA 9165 mandates that the marking, physical inventory, and photograph-taking of seized items must be conducted immediately after seizure. The law also requires the presence of the accused or their representative, along with representatives from the media and the Department of Justice (DOJ), and any elected public official. However, strict compliance is not always feasible, and the Implementing Rules and Regulations of RA 9165 provide a saving clause for justified procedural lapses, provided the prosecution can demonstrate that the integrity and evidentiary value of the seized evidence have been preserved.

In this instance, while a DOJ representative was absent, the police officers explained that they made earnest efforts to secure their presence. Further, representatives from the media and local government were present during the inventory. The court acknowledged the time-sensitive nature of buy-bust operations, which often rely on immediate action to prevent the escape of offenders or loss of evidence. The large quantity of drugs seized—over two kilos of cocaine—also mitigated the risk of tampering or planting of evidence, reinforcing the reliability of the evidence presented.

Regarding the defense’s claims of frame-up and extortion, the court found these allegations unsubstantiated. Accused-appellant failed to provide clear and convincing evidence to support these claims. Allegations of frame-up and extortion are common defenses in drug cases, but they require robust evidence to overcome the presumption of regularity in the performance of official duties by law enforcement officers.

In the Supreme Court’s analysis, it emphasized that the factual findings of the appellate court, affirming those of the trial court, are binding unless tainted with arbitrariness, capriciousness, or palpable error. Given the consistent findings of guilt and the demonstrated preservation of evidence, the Court found no reason to disturb the lower courts’ decisions.

In the end, this case is about balancing the need for effective drug law enforcement with the protection of individual rights. While strict adherence to procedural rules is ideal, the court recognized that justifiable deviations may occur, especially in dynamic situations like buy-bust operations. The key is to ensure that the integrity and evidentiary value of the seized items are preserved, safeguarding against planting, contamination, or loss of evidence. The case reinforces the importance of a robust chain of custody and the need for law enforcement to act with transparency and accountability, even when faced with practical challenges.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Appeals correctly affirmed the accused-appellant’s conviction for Illegal Sale and Illegal Use of Dangerous Drugs, considering the challenges in maintaining a perfect chain of custody.
What is a buy-bust operation?	A buy-bust operation is an entrapment technique used by law enforcement where an undercover officer poses as a buyer of illegal drugs to catch drug dealers in the act.
What is the ‘chain of custody’ in drug cases?	The chain of custody refers to the documented process of tracking seized evidence, ensuring its integrity from the moment of seizure to its presentation in court, accounting for each person who handled the evidence.
What are the requirements under Section 21 of RA 9165?	Section 21 of RA 9165 requires that seized drug evidence be immediately marked, inventoried, and photographed in the presence of the accused and representatives from the media, the DOJ, and an elected public official.
What happens if there are lapses in following Section 21?	If there are lapses, the prosecution must provide justifiable grounds for the omissions and demonstrate that the integrity and evidentiary value of the seized evidence were still preserved.
Why was the absence of a DOJ representative excused in this case?	The absence was excused because the police made earnest efforts to secure their presence, and the presence of media and local government officials, along with the large quantity of drugs seized, helped ensure the integrity of the evidence.
What is the significance of the quantity of drugs seized?	A large quantity of drugs reduces the likelihood of planting or tampering with evidence, making it more difficult for the accused to claim they were framed.
What is the difference between ‘entrapment’ and ‘instigation’?	Entrapment is a valid defense where the accused had no prior intent to commit the crime, while instigation occurs when law enforcement induces an innocent person to commit a crime they would not otherwise commit.
What evidence is needed to prove illegal drug use?	To prove illegal drug use, the prosecution typically presents initial and confirmatory drug test results confirming the presence of prohibited substances in the accused’s system.

In conclusion, the Supreme Court’s decision in People v. Vastine reinforces the importance of meticulous adherence to drug evidence protocols while acknowledging the practical realities faced by law enforcement during buy-bust operations. This ruling serves as a guide for balancing effective drug law enforcement with the protection of individual rights, emphasizing the need for accountability and transparency in handling drug evidence.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

November 29, 2022

Chain of Custody: Safeguarding Drug Evidence Integrity in Philippine Law

In People v. Fandialan, the Supreme Court acquitted the accused due to a failure in establishing an unbroken chain of custody for seized drugs. This means the prosecution didn’t sufficiently prove that the drugs presented in court were the same ones confiscated from the accused. The Court emphasized the importance of meticulously documenting and preserving drug evidence, highlighting a critical safeguard against potential mishandling or tampering. This decision reinforces the necessity of strict adherence to chain of custody procedures to ensure the integrity of evidence in drug-related cases, protecting individuals from wrongful convictions.

Breaking the Chain: When Doubt Acquits in Drug Cases

This case revolves around Joel Fandialan’s conviction for violating Sections 5 and 11, Article II of Republic Act No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002. Accused of selling and possessing methamphetamine hydrochloride (shabu), Fandialan faced life imprisonment and a substantial fine. The central legal question is whether the prosecution successfully established an unbroken chain of custody of the seized drugs, a crucial element in proving the corpus delicti of the offenses. The integrity of this chain determines the admissibility and reliability of the drug evidence presented in court.

The prosecution presented evidence that a buy-bust operation was conducted based on information from a confidential informant. PO1 Lubrin, acting as the poseur-buyer, allegedly purchased shabu from Fandialan. After the sale, Fandialan was arrested, and additional sachets of suspected shabu were found in his possession. The seized items were marked, inventoried, and photographed at the scene. However, the defense argued that Fandialan was merely apprehended while smoking in his yard, with the drugs and money allegedly planted by the arresting officers. This conflicting narrative underscores the importance of adhering to proper procedures to ensure the reliability of evidence.

The Supreme Court emphasized that in cases involving illegal drugs, the prosecution must establish the identity of the dangerous drug with moral certainty. This requires demonstrating an unbroken chain of custody, accounting for each link from seizure to presentation in court. As the Court noted in Mallillin v. People:

[T]he 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.

The Court identified four critical links in the chain of custody: (1) seizure and marking by the apprehending officer; (2) turnover to the investigating officer; (3) turnover to the forensic chemist for examination; and (4) submission of the drug from the forensic chemist to the court. While the prosecution established the first three links, the fourth link proved to be the downfall of their case.

The Court found a critical gap in the fourth link, specifically regarding the handling, storage, and safeguarding of the seized shabu after its examination by the forensic chemist, FC Bombasi. Although the parties stipulated to FC Bombasi’s expertise and the positive results of her examination, vital details were missing. As noted in People v. Villalon, Jr., it is essential for the forensic chemist to testify on:

…the details pertaining to the handling and analysis of the dangerous drug submitted for examination, i.e., when and from whom the dangerous drug was received; what identifying labels or other things accompanied it; description of the specimen; and the container it was in. Further, the forensic chemist must also identify the name and method of analysis used in determining the chemical composition of the subject specimen.

The stipulation failed to address the condition of the specimens upon receipt, the method of analysis, whether the specimens were resealed and marked after examination, and the manner of handling and storage before, during, and after the examination. This omission was critical. The absence of testimony regarding these details created reasonable doubt as to whether the drugs presented in court were indeed the same drugs seized from Fandialan. The Court referenced past decisions, such as People v. Dahil, People v. Miranda, and People v. Baltazar, where similar deficiencies led to acquittals.

The importance of the forensic chemist’s testimony or a comprehensive stipulation cannot be overstated. Without it, the integrity of the evidence is questionable. The Supreme Court has consistently emphasized that the prosecution bears the burden of proving each element of the offense beyond a reasonable doubt, including the unbroken chain of custody. Failure to do so warrants acquittal.

This case serves as a reminder of the stringent requirements for handling drug evidence in the Philippines. The chain of custody rule is not a mere technicality; it is a fundamental safeguard against tampering, contamination, and misidentification. The Court’s decision underscores the critical role of meticulous documentation and testimony in ensuring the reliability of drug evidence and protecting individuals from wrongful convictions. While the prosecution may have initially believed they had a strong case, the missing link in the chain of custody created sufficient doubt to warrant acquittal. This emphasis on procedural rigor is a cornerstone of Philippine criminal law, ensuring fair trials and protecting individual liberties.

Moreover, this case highlights the crucial role of forensic chemists in drug-related prosecutions. Their testimony is not merely perfunctory; it is essential for establishing the integrity and identity of the seized drugs. By meticulously documenting each step of the handling and analysis process, forensic chemists contribute to the reliability of the evidence presented in court. In the absence of such testimony, the prosecution’s case is significantly weakened, potentially leading to the acquittal of the accused.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution established an unbroken chain of custody for the seized drugs, which is essential to prove the identity and integrity of the evidence. The Court focused on a gap in the fourth link: the handling, storage, and safeguarding of the seized drugs after examination.
Why was the forensic chemist’s testimony important?	The forensic chemist’s testimony is crucial for detailing the handling and analysis of the dangerous drugs, including when and from whom the drug was received, the description of the specimen, the method of analysis, and the measures taken to preserve the integrity of the evidence. Without this testimony, doubt arises regarding the identity and integrity of the drug presented in court.
What are the four links in the chain of custody?	The four links are: (1) seizure and marking by the apprehending officer; (2) turnover to the investigating officer; (3) turnover to the forensic chemist for examination; and (4) submission of the drug from the forensic chemist to the court.
What happens if there is a break in the chain of custody?	If there is a break in the chain of custody, it creates reasonable doubt as to whether the drugs presented in court are the same as those seized from the accused. This can lead to the acquittal of the accused due to the compromised integrity of the evidence.
*What is the corpus delicti* in drug cases?**	The corpus delicti refers to the body of the crime, which in drug cases includes the actual dangerous drug itself. Establishing the identity and integrity of the drug is essential to prove the commission of the offense.
Why was the accused acquitted in this case?	The accused was acquitted because the prosecution failed to provide sufficient evidence regarding the handling, storage, and safeguarding of the seized drugs after their examination by the forensic chemist, creating a gap in the chain of custody.
What does this case highlight about drug-related prosecutions in the Philippines?	This case highlights the stringent requirements for handling drug evidence and the importance of meticulously documenting each step of the process to ensure the reliability of the evidence and protect individuals from wrongful convictions.
What is the role of stipulations in drug cases?	Stipulations can expedite the trial process, but they must be comprehensive enough to cover all essential aspects of the forensic chemist’s testimony, including the condition of the specimens, the method of analysis, and the measures taken to preserve the integrity of the evidence.

In conclusion, People v. Fandialan serves as a critical reminder of the importance of upholding the chain of custody rule in drug-related prosecutions. The meticulous preservation of evidence and the comprehensive documentation of its handling are essential to ensuring fair trials and protecting individual liberties. This case reinforces the need for law enforcement and forensic professionals to adhere strictly to established procedures, safeguarding the integrity of the criminal justice system.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

July 6, 2022

Chain of Custody and the Presumption of Regularity: Navigating Drug Cases in the Philippines

In the Philippines, convictions for drug-related offenses hinge on strict adherence to the chain of custody rule. This means that the prosecution must meticulously document and preserve the integrity of seized drugs from the moment of confiscation until they are presented as evidence in court. In People of the Philippines vs. Victor Alcira y Madriaga, the Supreme Court acquitted the accused on drug charges due to significant lapses in the chain of custody, while upholding his conviction for illegal possession of firearms, emphasizing the distinct nature of each offense and the stringent requirements for proving drug-related charges.

Buy-Bust Gone Wrong: When a Drug Case Unravels Due to Chain of Custody Lapses

The case began with a buy-bust operation launched against Victor Alcira, based on information that he was involved in drug sales and possessed an unlicensed firearm. During the operation, police officers allegedly caught Alcira selling shabu and found additional sachets of the drug and a firearm on his person. Alcira was subsequently charged with violations of Republic Act (R.A.) No. 9165, the Comprehensive Dangerous Drugs Act of 2002, and R.A. No. 10591, which concerns illegal possession of firearms. The Regional Trial Court (RTC) convicted Alcira on all counts, but the Court of Appeals (CA) affirmed this decision. Alcira then appealed to the Supreme Court, questioning the validity of the buy-bust operation, the legality of the search, and the integrity of the evidence.

At the heart of the Supreme Court’s decision was the **chain of custody rule**, a critical component of drug cases in the Philippines. Section 21 of R.A. No. 9165, as amended by R.A. No. 10640, outlines the specific procedures that law enforcement officers must follow when handling seized drugs. This includes immediate marking and inventory of the seized items, photographing them in the presence of the accused, an elected public official, and a representative from the National Prosecution Service or the media. The seized drugs must then be turned over to the PNP Crime Laboratory within 24 hours for examination.

The purpose of the chain of custody rule is to ensure the identity and integrity of the seized drugs, preventing tampering or substitution. As the Supreme Court emphasized, strict adherence to these procedures is crucial because dangerous drugs are not easily identifiable and can be easily compromised. Any significant lapses in the chain of custody can cast doubt on the evidence and potentially lead to the acquittal of the accused. In this case, the Court found several critical flaws in the prosecution’s handling of the seized drugs.

One of the primary issues was the **lack of photographs** of the seized items. R.A. No. 10640 explicitly requires that photographs be taken immediately after the seizure. While SPO1 Janairo claimed photographs were taken, no such evidence was presented in court. The Supreme Court found this omission significant, noting that modern technology makes it easy for law enforcement officers to comply with this requirement. The Court quoted People v. Placiente, stating that the failure to take photographs was a serious oversight, especially when virtually all cellular phones are equipped with cameras.

Another crucial break in the chain of custody occurred in the **transfer of evidence**. The Supreme Court pointed out inconsistencies regarding the turnover of the seized drugs from the apprehending officer to the investigating officer. SPO1 Janairo testified that he maintained possession of the items until delivering them to the crime laboratory. However, the Request for Laboratory Examination bore the signature of the Chief of Police, P/Supt. Ortega. This discrepancy raised questions about who handled the evidence and whether proper procedures were followed. The Court cited People v. Cupcupin, emphasizing the investigating officer’s responsibility to account for how they handled the evidence to prevent tampering.

Furthermore, the prosecution **failed to present the testimony of the forensic chemist**, PCI Huelgas, who examined the seized drugs. While the parties stipulated that the specimens examined were the same specimens presented in court, there was no testimony or evidence regarding how PCI Huelgas ensured the integrity of the drugs while in her custody. The Supreme Court referenced People v. Gutierrez, where a similar lack of testimony from the forensic chemist led to the accused’s acquittal. In that case, the stipulations failed to establish the condition of the seized item or that there was no opportunity to identify the individual in possession thereof.

Due to these cumulative lapses in the chain of custody, the Supreme Court concluded that the prosecution had failed to prove the integrity of the corpus delicti, the body of the crime. This failure, the Court held, warranted the acquittal of Alcira on the drug charges. The Court reaffirmed the principle that the chain of custody rule is not a mere technicality but a matter of substantive law. As the amount of illegal drugs seized was small, the risk of tampering increased the necessity for stricter adherence to the rule of chain of custody, the Court emphasized.

However, the Supreme Court **upheld Alcira’s conviction for illegal possession of firearms** under R.A. No. 10591. The Court distinguished this offense from the drug charges, stating that it is a separate and distinct crime that can proceed independently. The elements of illegal possession of firearms are: (1) the existence of the firearm, and (2) the lack of a license or permit for the accused to possess it. The prosecution presented a certification from the Firearms and Explosives Office confirming that Alcira was not authorized to possess the .38 revolver found on his person.

The Court addressed Alcira’s argument that the buy-bust operation was irregular, noting that the **absence of prior surveillance** is not necessarily fatal to the prosecution’s case. The Court stated that there is no single method for conducting buy-bust operations and that police authorities have discretion in choosing effective means to apprehend drug dealers. In this case, the presence of a confidential informant who positively identified Alcira as the target made prior surveillance unnecessary. Further, the Court dismissed the argument that the buy-bust money was not marked or that there was no pre-arranged signal. The court emphasized flexibility for police officers to effectively apprehend drug suspects.

In examining whether the buy-bust operation was valid, the Supreme Court applied the **objective test** outlined in People v. Doria. This test requires a clear and adequate showing of the details of the transaction, from initial contact to the delivery of the illegal drug. In this case, the Court found that the prosecution had sufficiently established the elements of the buy-bust operation. Despite this finding, the Court underscored that even in the presence of a valid buy-bust operation, an accused may still be acquitted if the prosecution fails to adequately account for the corpus delicti.

Regarding the relevance of a ballistics examination, the Supreme Court noted that it was **unnecessary** for the charge of illegal possession of firearms. A ballistics exam is typically conducted to determine whether a bullet was fired from a specific weapon, a fact not relevant to the charge in this case. The prosecution only needed to prove that Alcira possessed the firearm without the required license or authority.

As a result, the Supreme Court modified the penalty imposed by the lower courts, sentencing Alcira to an indeterminate prison term ranging from eight years, eight months, and one day to ten years, eight months, and one day. The Court emphasized that even if the firearm was acquired due to an otherwise defective operation, the lack of integrity in a crime does not automatically invalidate another separate and distinct crime which was committed.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution adequately established the chain of custody for the seized drugs and whether that failure affected the conviction for both drug offenses and illegal possession of firearms.
Why was the accused acquitted of the drug charges?	The accused was acquitted of the drug charges due to significant lapses in the chain of custody, including the lack of photographs of the seized items, inconsistencies in the transfer of evidence, and the failure to present the testimony of the forensic chemist.
What is the chain of custody rule?	The chain of custody rule is a legal requirement that mandates the prosecution to meticulously document and preserve the integrity of seized drugs from the moment of confiscation until they are presented as evidence in court, ensuring they are not tampered with or substituted.
Why is the chain of custody rule so important in drug cases?	The chain of custody rule is important because dangerous drugs are not easily identifiable and can be easily tampered with or substituted, making it essential to ensure the integrity of the evidence presented in court.
Was the buy-bust operation in this case valid?	The Supreme Court found that the buy-bust operation was valid, as the prosecution established the elements of the transaction from initial contact to the delivery of the illegal drug.
Why was the accused still convicted of illegal possession of firearms?	The accused was convicted of illegal possession of firearms because the prosecution proved that he possessed a firearm without the required license or authority, a separate and distinct offense from the drug charges.
What is the significance of a ballistics examination in this case?	A ballistics examination was deemed unnecessary in this case because the charge was for illegal possession of firearms, not for using the firearm to commit a crime.
What does the objective test in buy-bust operations entail?	The objective test requires a clear and adequate showing of the details of the transaction, from initial contact to the delivery of the illegal drug, ensuring that law-abiding citizens are not unlawfully induced to commit an offense.

This case serves as a reminder of the critical importance of adhering to the chain of custody rule in drug cases. While the presumption of regularity may apply to law enforcement actions, it cannot excuse significant lapses in preserving the integrity of evidence. The Supreme Court’s decision underscores the need for meticulous documentation and handling of seized drugs to ensure fair and just outcomes in drug-related prosecutions.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

June 22, 2022

Tag: corpus delicti

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