In People v. Benedicto Veedor, Jr., the Supreme Court acquitted the accused due to the prosecution’s failure to prove an unbroken chain of custody of the seized drugs. This means the prosecution couldn’t definitively prove the marijuana presented in court was the same substance confiscated from Veedor. The ruling underscores the critical importance of meticulously following the procedures outlined in Republic Act No. 9165, emphasizing that any break in the chain of custody can lead to reasonable doubt and ultimately, an acquittal.

From ‘Dried Leaves’ to ‘Flowering Tops’: When Discrepancies in Drug Evidence Lead to Doubt

The case of People of the Philippines v. Benedicto Veedor, Jr. arose from a search warrant executed at Veedor’s residence. During the search, NBI agents found a shopping bag and several plastic sachets containing suspected marijuana. Veedor was subsequently charged with illegal possession of dangerous drugs under Section 11, Article II of Republic Act No. 9165 (RA 9165). The central legal question revolved around whether the prosecution successfully established an unbroken chain of custody for the seized drugs, a crucial element in drug-related cases to ensure the integrity and identity of the evidence.

The prosecution presented evidence indicating that SI Escurel marked the seized items and prepared an inventory in the presence of witnesses. Forensic Chemist Aranas later confirmed the substances as marijuana. However, several inconsistencies and procedural lapses cast doubt on the integrity of the evidence. One critical issue was the NBI agents’ failure to account for and mark the 323 plastic sachets reportedly found within the seized plastic bags. This oversight raised questions about whether those specific sachets were indeed part of the original seizure.

Furthermore, a significant discrepancy emerged in the description of the seized drugs. Initial reports from the NBI agents referred to “dried marijuana leaves,” while the forensic chemist identified the substance as “crushed dried marijuana flowering tops.” This inconsistency, left unaddressed by the prosecution, created uncertainty regarding the precise nature of the seized substance. The Supreme Court has consistently held that, in drug-related cases, the dangerous drug itself constitutes the corpus delicti, and its identity must be established beyond a reasonable doubt. In Derilo v. People, the Supreme Court explained that:

A successful prosecution for the sale of illegal drugs requires more than the perfunctory presentation of evidence establishing each element of the crime: the identities of the buyer and seller, the transaction or sale of the illegal drug and the existence of the corpus delicti. In securing or sustaining a conviction under RA No. 9165, the intrinsic worth of these pieces of evidence, especially the identity and integrity of the corpus delicti, must definitely be shown to have been preserved.

Moreover, the original Inventory of Seized Property and photographs taken at the scene were not properly submitted as evidence. This failure further weakened the prosecution’s case, as these items could have helped verify the identity and condition of the seized drugs. The Court also considered the testimony of Brgy. Chairman Francisco, a prosecution witness, who stated that the items presented in court differed from what he witnessed during the search. His testimony further eroded confidence in the reliability of the evidence.

The concept of the chain of custody, as outlined in Section 21, Article II of RA 9165, is designed to ensure the integrity of seized drugs from the moment of confiscation to their presentation in court. This section mandates specific procedures for handling and documenting seized items. Section 21 provides the procedural safeguards that the apprehending team should observe in the handling of seized illegal drugs in order to remove all doubts concerning the identity of the corpus delicti. As indicated by their mandatory terms, strict compliance with the prescribed procedure is essential and the prosecution must show compliance in every case.

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 PDEA shall take charge and have custody of all dangerous drugs, x x x so confiscated, seized and/or surrendered, for proper disposition in the following manner:

(1) The apprehending team having initial custody and control of the dangerous drugs, x x x shall, immediately after seizure and confiscation, conduct a physical inventory of the seized items and photograph the same in the presence of the accused or the persons from whom such items were confiscated and/or seized, or his/her representative or counsel, 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 and be given a copy thereof; Provided, That the physical inventory and photograph shall be conducted at the place where the search warrant is served; or at the nearest police station or at the nearest office of the apprehending officer/team, whichever is practicable, in case of warrantless seizures: Provided, finally, That noncompliance of these requirements under justifiable grounds, as long as the integrity and the evidentiary value of the seized items are properly preserved by the apprehending officer/team, shall not render void and invalid such seizures and custody over said items.

The Supreme Court identified several breaks in the chain of custody in this case. The failure to mark the 323 plastic sachets, the discrepancy in the description of the drugs, and the lack of clarity regarding who had custody of the evidence at various points all contributed to the Court’s decision. The Court emphasized that to show an unbroken chain of custody, the prosecution’s evidence must include testimony about every link in the chain, from the moment the dangerous drug was seized to the time it is offered in court as evidence.

The Court emphasized the critical importance of accurately conducting an inventory of seized drugs and related items to protect both the integrity of the evidence and the rights of the accused. The Court also noted gaps in the evidentiary chain: the prosecution failed to disclose the identities of those who handled the seized items after SI Escurel and before their presentation in court. In essence, the Court found that the prosecution’s case was riddled with doubts and inconsistencies. Due to the failure to prove the corpus delicti beyond a reasonable doubt, the Supreme Court acquitted Benedicto Veedor, Jr.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution proved an unbroken chain of custody for the seized drugs, which is essential to ensure the integrity and identity of the evidence in drug-related cases. The Supreme Court found that the prosecution failed to establish this, leading to the accused’s acquittal.
What is the significance of the ‘chain of custody’ in drug cases?	The chain of custody refers to the documented process of tracking seized evidence from the moment of confiscation to its presentation in court. It’s crucial because it ensures that the evidence presented is the same evidence seized from the accused, preventing tampering or substitution.
What were the main problems with the evidence in this case?	The main problems included the failure to properly mark and inventory all seized items (specifically, the 323 plastic sachets), inconsistencies in the description of the drugs (dried leaves vs. flowering tops), and gaps in documenting who had custody of the evidence at various stages.
Why was the testimony of the Barangay Chairman important?	The Barangay Chairman, a prosecution witness, testified that the items presented in court differed from what he saw during the search. This cast further doubt on the reliability of the evidence and contributed to the Court’s decision to acquit.
What is ‘corpus delicti’ and why is it important in drug cases?	‘Corpus delicti’ refers to the body of the crime, or the actual substance that constitutes the illegal drug. In drug cases, proving the identity and integrity of the corpus delicti beyond a reasonable doubt is essential for a conviction.
What does RA 9165 say about handling seized drugs?	RA 9165 (Comprehensive Dangerous Drugs Act of 2002) outlines specific procedures for handling seized drugs, including immediate inventory, photographing the items, and maintaining a clear chain of custody. These procedures are designed to prevent tampering and ensure the integrity of the evidence.
What happens if the police fail to follow the procedures in RA 9165?	If the police fail to follow the procedures outlined in RA 9165, it can cast doubt on the integrity of the evidence and potentially lead to an acquittal. However, non-compliance may be excused under justifiable grounds, provided the integrity and evidentiary value of the seized items are preserved.
What was the final decision of the Supreme Court in this case?	The Supreme Court reversed the Court of Appeals’ decision and acquitted Benedicto Veedor, Jr. of the charge of illegal possession of dangerous drugs. This decision was based on the prosecution’s failure to prove his guilt beyond a reasonable doubt due to the broken chain of custody.

This case reinforces the stringent requirements for handling drug-related evidence in the Philippines. Law enforcement agencies must adhere strictly to the chain of custody procedures outlined in RA 9165 to ensure the admissibility and reliability of evidence in court. Failure to do so can have significant consequences, including the dismissal of charges and the acquittal of the accused.

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 v. Veedor, Jr., G.R. No. 223525, June 25, 2018