In drug-related cases, the integrity of the evidence is paramount. The Supreme Court held in People v. Casacop that failure to adhere to the strict chain of custody requirements outlined in Section 21 of Republic Act No. 9165, or failure to sufficiently justify any deviation from these procedures, introduces reasonable doubt regarding the integrity of the corpus delicti, i.e., the body of the crime. This means that without a clear, unbroken trail of evidence, a conviction cannot stand, protecting individuals from potential miscarriages of justice in drug cases.

When a Shabu Sachet’s Journey Becomes a Legal Labyrinth

The case revolves around Rodrigo Casacop, who was accused of selling 0.04 grams of methamphetamine hydrochloride, commonly known as shabu, during a buy-bust operation. The prosecution presented PO1 Rommel Bautista, who testified about the operation and the subsequent arrest of Casacop. However, the defense argued that the chain of custody of the seized drugs was compromised, raising doubts about the integrity of the evidence. The Regional Trial Court convicted Casacop, a decision later affirmed by the Court of Appeals. The Supreme Court, however, took a different view, focusing on the critical importance of maintaining an unbroken chain of custody for seized drugs.

The Supreme Court emphasized the importance of the chain of custody, referring to the duly recorded authorized movements and custody of seized drugs from the time of seizure or recovery to receipt in the forensic laboratory to safekeeping, and presentation in court for identification. The Court cited Section 21 of Republic Act No. 9165, which meticulously outlines how law enforcement officers must handle seized items in drug cases. Specifically, the law states:

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

1. The apprehending team having initial custody and control of the drugs shall, immediately after seizure and confiscation, physically inventory and photograph the same in the-presence of the accused or the person/s from whom such items were confiscated and/or seized, or his/her representative or counsel, a representative from the media and the Department of Justice (DOJ), and any elected public official who shall be required to sign the copies of the inventory and be given a copy thereof;

The Court also acknowledged that strict compliance isn’t always possible, noting the Implementing Rules and Regulations of Republic Act No. 9165, which allows for justifiable grounds for non-compliance, provided the integrity and evidentiary value of the seized items are properly preserved. However, it is crucial to satisfy that the justifiable grounds exist and were met.

In analyzing the facts, the Court found several critical breaks in the chain of custody. First, there was doubt as to whether the item allegedly handed over by Casacop to the poseur-buyer was the same item presented as evidence, as PO1 Bautista only witnessed the transaction from a distance. Second, the testimony was silent on where the seized sachet was marked, a crucial step in identifying the evidence. The Supreme Court referenced People v. Sabdula, highlighting that marking must be done in the presence of the apprehended violator. Third, the prosecution failed to identify who turned over the seized sachet to the Philippine National Police Crime Laboratory, creating another break in the chain. Finally, a discrepancy existed regarding the identity of the police officer who examined the contents of the sachet, further undermining the integrity of the corpus delicti. The Court noted that inconsistencies in testimonies also put reasonable doubt as to the commission of the crime.

Building on these points, the Court emphasized the miniscule amount of drugs involved (0.04 grams), citing People v. Holgado to highlight the need for exacting compliance with Section 21 when dealing with such small quantities, due to the increased risk of tampering or contamination. In the case of People v. Holgado the court said,

Compliance with the chain of custody requirement provided by Section 21, therefore, ensures the integrity of confiscated, seized, and/or surrendered drugs and/or drug paraphernalia in four (4) respects: first, the nature of the substances or items seized; second, the quantity (e.g., weight) of the substances or items seized; third, the relation of the substances or items seized to the incident allegedly causing their seizure; and fourth, the relation of the substances or items seized to the person/s alleged to have been in possession of or peddling them. Compliance with this requirement forecloses opportunities for planting, contaminating, or tampering of evidence in any manner.

Furthermore, the Court found the non-presentation of the poseur-buyer to be detrimental to the prosecution’s case, as this individual had direct knowledge of the transaction, unlike PO1 Bautista, who was merely an observer. Other procedural lapses, such as the failure to conduct an inventory or photograph the seized items, further weakened the prosecution’s case. The police officer also failed to show that there was a pre-operation report that was prepared and no written authority from the Chief of Police to conduct the buy-bust operation.

Acknowledging the prosecution’s argument regarding the presumption of regularity in the performance of official duties, the Court reiterated that this presumption cannot override the accused’s constitutional right to be presumed innocent. As the court in People v. Ong said,

To determine whether there was a valid entrapment or whether proper procedures were undertaken in effecting the buy-bust operation, it is incumbent upon the courts to make sure that the details of the operation are clearly and adequately laid out through relevant, material and competent evidence. For, the courts could not merely rely on but must apply with studied restraint the presumption of regularity in the performance of official duty by law enforcement agents.

Because of the failure to comply with Section 21 of Republic Act No. 9165 and the failure to prove guilt beyond reasonable doubt, the Supreme Court reversed the Court of Appeals’ decision and acquitted Rodrigo Casacop. The court also reminded law enforcement and prosecutors to focus on larger drug operations rather than expending resources on small-time users and retailers.

FAQs

What is the chain of custody in drug cases?	It refers to the documented sequence of possession and control of evidence, ensuring its integrity from seizure to presentation in court. This involves proper handling, labeling, storage, and transfer of evidence to prevent contamination or tampering.
Why is the chain of custody important?	The chain of custody is crucial to ensure the reliability and admissibility of evidence in court. A broken chain can cast doubt on the authenticity of the evidence, potentially leading to acquittal.
What happens if the chain of custody is broken?	If the chain of custody is broken, the integrity of the evidence is compromised, making it difficult for the prosecution to prove its case beyond a reasonable doubt. The court may exclude the evidence, leading to acquittal.
What is Section 21 of Republic Act No. 9165?	Section 21 outlines the procedures for handling and custody of seized drugs, including immediate inventory and photography in the presence of the accused, media, DOJ representative, and an elected official. It ensures transparency and accountability in handling drug evidence.
What are justifiable grounds for non-compliance with Section 21?	Justifiable grounds are circumstances that prevent strict compliance with Section 21, such as safety concerns or lack of available witnesses. However, the prosecution must prove these grounds and demonstrate that the integrity of the evidence was still preserved.
What role does the poseur-buyer play in a buy-bust operation?	The poseur-buyer is the individual who pretends to purchase drugs from the suspect. Their testimony is crucial as they have direct knowledge of the transaction.
What is the presumption of regularity in the performance of official duties?	It’s a legal principle that assumes law enforcement officers act in accordance with the law. However, this presumption cannot override the accused’s right to be presumed innocent and must be supported by evidence.
What should law enforcers do to improve drug case prosecutions?	Law enforcers should meticulously comply with Section 21, properly document every step, and focus on larger drug operations. Transparent and accountable procedures are essential for successful prosecutions.

The Casacop case serves as a potent reminder of the meticulous care required in handling drug evidence. By strictly adhering to chain of custody protocols, law enforcement agencies can bolster the integrity of their cases and ensure that justice is served fairly. This case underscores the importance of protecting individual rights and preventing wrongful convictions, even in the pursuit of combating drug-related crimes.

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. RODRIGO CASACOP, G.R. No. 208685, March 09, 2015