In People v. Jocelyn Carlit y Gawat, the Supreme Court acquitted the accused due to the prosecution’s failure to establish an unbroken chain of custody for the seized drugs, highlighting the crucial importance of preserving the integrity and identity of evidence in drug-related cases. This decision emphasizes that the prosecution must prove every link in the chain of custody beyond reasonable doubt, and any failure to do so can lead to acquittal. The ruling underscores the court’s commitment to protecting individual liberties and ensuring fair trials, especially in cases involving potentially life-altering penalties.

Unraveling Reasonable Doubt: How a Broken Chain of Custody Freed Jocelyn Carlit

The case began with a buy-bust operation conducted by PO3 Christian Carvajal against Jocelyn Carlit for allegedly selling methamphetamine hydrochloride, or shabu. According to the prosecution, PO3 Carvajal acted as the poseur-buyer and purchased a sachet of shabu from Carlit using marked money. Carlit was then arrested, and the seized substance was marked and sent to the PNP Crime Laboratory for examination. PSI Myrna Malojo Todeño, the forensic chemist, confirmed that the substance tested positive for methamphetamine hydrochloride.

Carlit was charged with violating Section 5 of Republic Act No. (R.A.) 9165, the Comprehensive Dangerous Drugs Act of 2002, for the illegal sale of dangerous drugs. The Regional Trial Court (RTC) found Carlit guilty beyond reasonable doubt, sentencing her to life imprisonment and a fine of Five Hundred Thousand (P500,000.00) Pesos. The Court of Appeals (CA) affirmed the RTC’s decision. However, the Supreme Court reversed the CA’s ruling and acquitted Carlit, focusing on critical flaws in the prosecution’s handling of evidence.

The Supreme Court emphasized that in cases involving the illegal sale of dangerous drugs, the prosecution must establish two essential elements: (1) the identity of the buyer and seller, the object of the sale, and the consideration; and (2) the delivery of the thing sold and payment therefor. More importantly, the Court stressed the need to present the corpus delicti, or the body of the crime, in court. Due to the unique characteristics of narcotic substances, which are prone to tampering, alteration, or substitution, the Court requires a more exacting standard for their admission as evidence. This is where the observance of the chain of custody becomes crucial.

The chain of custody refers to the “duly recorded authorized movements and custody of seized drugs or controlled chemicals or plant sources of dangerous drugs or laboratory equipment of each stage, from the time of seizure/confiscation to receipt in the forensic laboratory to safekeeping to presentation in court.” People v. Salvador (Salvador) articulates the critical links in the chain of custody in a buy-bust situation:

There are links that must be established in the chain of custody in a buy-bust situation, namely: “first, the seizure and marking, if practicable, of the illegal drug recovered from the accused by the apprehending officer; second, the turnover of the illegal drug seized by the apprehending officer to the investigating officer; third, the turnover by the investigating officer of the illegal drug to the forensic chemist for laboratory examination; and, fourth, the turnover and submission of the marked illegal drug seized from the forensic chemist to the court.”

In Carlit’s case, the Supreme Court found that the prosecution failed to prove every link in the chain of custody. The prosecution presented PO3 Carvajal, who testified about seizing the sachet from Carlit and turning it over to PSI Todeño at the PNP Crime Laboratory. PSI Todeño confirmed receiving the substance and then handing it over to PO2 Manuel, the evidence custodian. It was the failure to present PO2 Manuel as a witness that the Supreme Court found most troubling.

The Court explained that the final link in the chain must demonstrate how the seized drug item came into the court’s physical custody. The risk of tampering, alteration, or substitution exists every time the prohibited item is stored or transported. Therefore, presenting PO2 Manuel’s testimony, and anyone else who handled the drug after him, was essential. Without PO2 Manuel’s testimony, there was no guarantee that the corpus delicti had been preserved. As the Court stated in People v. Barba:

x x x x A conviction cannot be sustained if there is a persistent doubt on the identity of the drug. The identity of the prohibited drug must be established with moral certainty. Apart from showing that the elements of possession or sale are present, the fact that the substance illegally possessed and sold in the first place is the same substance offered in court as exhibit must likewise be established with the same degree of certitude as that needed to sustain a guilty verdict.

In addition to the broken chain of custody, the Supreme Court also noted that the arresting officers failed to comply with the procedural guidelines laid down in Paragraph 1, Section 21 of R.A. 9165, as amended by R.A. 10640. This provision requires that:

the apprehending team having initial custody and control of the dangerous drugs, controlled precursors and essential chemicals, instruments/paraphernalia and/or laboratory equipment shall, immediately after seizure and confiscation, conduct a physical inventory of the seized items and photograph the same in the presence of the accused or the person/s from whom such items were confiscated and/or seized, or his/her representative or counsel, 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.

While there are exceptions to the strict compliance with Section 21, the Court emphasized that these exceptions apply only when there are justifiable grounds for non-compliance, and the integrity and evidentiary value of the seized items are properly preserved. As elucidated in People v. Bartolini:

However, this non-compliance is not fatal only when there are (1) justifiable grounds and (2) the integrity and evidentiary value of the seized items are properly preserved.

In Carlit’s case, PO3 Carvajal testified that he marked the alleged shabu at the police station instead of immediately at the place of arrest. The arresting officers also failed to ensure the presence of an elected public official and a representative of the National Prosecution Service or the media during the inventory. The failure to provide any justifiable explanation for these lapses raised serious doubts about whether the chain of custody was actually unbroken. As emphasized in People v. Cayas, strict compliance is generally required due to the unique characteristics of illegal drugs that make them susceptible to tampering or substitution.

Ultimately, the Supreme Court concluded that the prosecution failed to prove that the chain of custody was unbroken due to the absence of the evidence custodian’s testimony and non-compliance with Paragraph 1, Section 21 of RA 9165, as amended, without justifiable reason. As a result, the guilt of the accused-appellant was not proven beyond a reasonable doubt, warranting her acquittal.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution sufficiently proved an unbroken chain of custody for the seized drugs, which is essential for establishing the corpus delicti in drug-related cases.
Why is the chain of custody important in drug cases?	The chain of custody ensures the integrity and identity of the seized drugs, preventing tampering, alteration, or substitution of evidence. It is crucial for protecting the rights of the accused and ensuring a fair trial.
What are the required links in the chain of custody?	The required links include the seizure and marking of the drug, turnover to the investigating officer, turnover to the forensic chemist, and submission of the drug to the court. Each transfer must be properly documented.
What happens if the chain of custody is broken?	If the chain of custody is broken, the integrity and identity of the evidence are compromised, creating reasonable doubt as to the guilt of the accused. This can lead to acquittal.
What does Section 21 of R.A. 9165 require?	Section 21 requires the apprehending team to immediately conduct a physical inventory and photograph the seized items in the presence of the accused, an elected public official, and a representative of the National Prosecution Service or the media.
Are there exceptions to the requirements of Section 21?	Yes, non-compliance may be excused if there are justifiable grounds and the integrity and evidentiary value of the seized items are properly preserved. However, the prosecution must explain the reasons for non-compliance.
Why was the accused acquitted in this case?	The accused was acquitted because the prosecution failed to present the testimony of the evidence custodian and did not comply with Section 21 of R.A. 9165 without providing justifiable reasons, thus failing to prove an unbroken chain of custody.
What is the significance of this ruling?	This ruling reinforces the importance of strict adherence to procedural safeguards in drug cases to protect individual liberties and ensure fair trials. It emphasizes that the prosecution bears the burden of proving every element of the crime beyond a reasonable doubt.

People v. Jocelyn Carlit y Gawat serves as a reminder of the stringent requirements for handling evidence in drug-related cases. This decision underscores the need for law enforcement to meticulously follow the prescribed procedures to safeguard the rights of the accused and uphold the principles of justice. Moving forward, strict compliance with chain of custody rules is crucial to ensure the integrity of evidence and fairness in drug enforcement.

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

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People v. Jocelyn Carlit y Gawat, G.R. No. 227309, August 16, 2017