In People v. Teng Moner, the Supreme Court affirmed the conviction for illegal drug sale, emphasizing that strict adherence to the chain of custody rule isn’t mandatory if the integrity and evidentiary value of the seized drugs are preserved. This means that even if law enforcement officers don’t follow every step of the prescribed procedure perfectly, a conviction can still stand if there’s strong evidence the drugs presented in court are the same ones seized from the accused. This decision highlights a balance between procedural safeguards and the pursuit of justice, acknowledging real-world challenges in law enforcement while protecting defendants’ rights.

When Security Concerns Override Strict Drug Evidence Handling

The case revolves around Teng Moner’s conviction for selling 3.91 grams of methylamphetamine hydrochloride (shabu) following a buy-bust operation. Moner appealed, arguing that the prosecution failed to prove his guilt beyond a reasonable doubt, pointing to inconsistencies in the testimonies of the police officers and their failure to comply with the mandatory procedures for handling seized drugs, as outlined in Section 21 of Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002. Specifically, Moner highlighted the lack of proper coordination with the Philippine Drug Enforcement Agency (PDEA) and the failure to conduct a physical inventory and photograph the seized drugs in the presence of required witnesses.

The prosecution presented PO2 Joachim Panopio, who acted as the poseur-buyer, positively identified Moner as the seller. The Court addressed Moner’s contention regarding the absence of the informant, reiterating that informants aren’t indispensable witnesses and that PO2 Panopio’s testimony, along with those of other buy-bust team members, was sufficient. The Court also dismissed the alleged inconsistencies in the testimonies as minor variances that didn’t detract from the central fact of the drug sale. This ruling underscores the importance of the poseur-buyer’s testimony in buy-bust operations and emphasizes that minor inconsistencies do not automatically discredit witness testimonies.

Regarding the chain of custody, the Court acknowledged that the apprehending officers didn’t strictly comply with Section 21 of R.A. No. 9165, which mandates the immediate physical inventory and photography of seized drugs in the presence of the accused, a media representative, a DOJ representative, and an elected public official. Moner argued that the inventory wasn’t conducted at the place of seizure and that required witnesses were absent. However, the Court noted that the inventory and marking of the drugs were done at the Las Piñas Police Station, where Moner and his co-accused were taken for processing. This deviation from the prescribed procedure was justified by the officers’ concern for their security, as they were operating outside their area of responsibility. The Court emphasized that non-compliance with Section 21 doesn’t automatically render the seized drugs inadmissible if the integrity and evidentiary value of the drugs are preserved.

The chain of custody rule, as defined by the Dangerous Drugs Board (DDB), requires a duly recorded account of authorized movements and custody of seized drugs from the moment of seizure to presentation in court. The purpose is to ensure the integrity of the evidence and prevent tampering. Section 21(a) of the Implementing Rules and Regulations (IRR) of R.A. No. 9165 allows for deviations from the strict requirements under justifiable grounds, provided the integrity and evidentiary value of the seized items are preserved. The police officers testified that they made an inventory report.

The Court cited Palo v. People, stating, “The fact that the apprehending officer marked the plastic sachet at the police station, and not at the place of seizure, did not compromise the integrity of the seized item. Jurisprudence has declared that ‘marking upon immediate confiscation’ contemplates even marking done at the nearest police station or office of the apprehending team.” The Court also cited People v. Usman, where it upheld a conviction despite the lack of photographs of the seized drugs, emphasizing that the most important factor is the preservation of the integrity and evidentiary value of the seized items.

In evaluating the chain of custody, the Court emphasized that the primary concern is whether the integrity and evidentiary value of the seized items have been preserved. Even if there are procedural lapses, the evidence can still be admissible if there is no doubt that the drugs presented in court are the same ones seized from the accused. Regarding the absence of required witnesses during the inventory, the Court noted that the police officers did not provide a clear justification for their absence, which is a deviation from standard procedure. However, this deviation alone did not invalidate the seizure, as the Court found that the integrity and evidentiary value of the seized drugs were otherwise preserved.

Furthermore, the Court addressed Moner’s allegation that the buy-bust team attempted to extort money from him and his co-accused. The Court noted that this allegation was only raised during Moner’s testimony and was not presented to the prosecution witnesses for cross-examination. The Court also reiterated that the defense of denial or frame-up is viewed with disfavor, as it can be easily concocted. The Court emphasized the presumption that police officers perform their duties in a regular manner, unless there is evidence to the contrary. The Court found that Moner failed to provide clear and convincing evidence to overturn this presumption.

The dissenting opinion argued that the police officers’ deviation from the chain of custody procedure was not justified, as they failed to provide a sufficient explanation for the absence of the required witnesses during the inventory. The dissent emphasized that the prosecution has a positive duty to account for any lapses in the chain of custody, and that failure to do so compromises the integrity and evidentiary value of the seized items. Citing People v. Miranda, the dissent asserted that the State has a positive duty to account for lapses in the chain of custody, regardless of whether the defense raises the issue. Despite the dissenting opinion’s arguments, the majority of the Court maintained that the conviction should be upheld, as the prosecution demonstrated that the integrity and evidentiary value of the seized drugs were preserved, even with the procedural deviations.

Ultimately, the Supreme Court’s decision in People v. Teng Moner reflects a pragmatic approach to drug cases, recognizing that strict adherence to procedural rules isn’t always possible in the field. The Court prioritizes the preservation of the integrity and evidentiary value of the seized drugs, allowing for convictions even when there are minor deviations from the prescribed chain of custody procedure. The analysis leads to the understanding that the law is on the side of justice.

FAQs

What is the chain of custody rule?	The chain of custody rule requires a documented record of each person who handled evidence, the date and time it was collected or transferred, and the purpose of the transfer. This ensures the integrity of the evidence presented in court.
What is required under Section 21 of R.A. 9165?	Section 21 of R.A. 9165, before amendment, requires that seized drugs be inventoried and photographed immediately after seizure in the presence of the accused, a media representative, a DOJ representative, and an elected public official.
What happens if the police don’t follow Section 21?	Non-compliance with Section 21 doesn’t automatically invalidate the seizure if the prosecution can prove there was a justifiable reason for the non-compliance and that the integrity and evidentiary value of the seized items were preserved.
What was the main issue in this case?	The main issue was whether the failure of the police to strictly comply with the chain of custody requirements invalidated the accused’s conviction for selling illegal drugs.
Why did the police deviate from the standard procedure?	The police claimed they deviated from the standard procedure due to security concerns, as they were operating outside their area of responsibility and wanted to leave the area quickly.
Did the prosecution present the informant in court?	No, the prosecution did not present the informant. The Court ruled that the informant’s testimony was not indispensable, as the poseur-buyer and other members of the buy-bust team testified.
What did the dissenting justice argue?	The dissenting justice argued that the police failed to provide a sufficient justification for the absence of required witnesses during the inventory, compromising the integrity of the seized items.
What is the key takeaway from this case?	The key takeaway is that substantial compliance with the chain of custody rule is sufficient if the integrity and evidentiary value of the seized drugs are preserved, even if there are minor procedural deviations.

This case underscores the delicate balance between upholding procedural safeguards and ensuring that those who violate drug laws are brought to justice. While strict compliance with the chain of custody rule is ideal, the Supreme Court recognizes that real-world law enforcement often presents challenges that may necessitate deviations from the prescribed procedure. As long as the integrity and evidentiary value of the seized drugs are preserved, a conviction can stand, reinforcing the importance of thorough and reliable evidence in drug cases.

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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. Teng Moner y Adam, G.R. No. 202206, March 05, 2018