In the Philippine legal system, the integrity of evidence is paramount, especially in drug-related cases. The Supreme Court in People v. Feriol acquitted the accused due to the prosecution’s failure to establish an unbroken chain of custody for the seized drugs. This means the prosecution did not adequately prove that the evidence presented in court was the same item seized from the accused, raising doubts about its integrity. This ruling highlights the crucial need for law enforcement to strictly adhere to procedural safeguards to protect the rights of the accused and maintain the integrity of the judicial process. It serves as a stern reminder that any deviation from the established protocols, without justifiable explanation, can undermine the validity of the evidence and lead to acquittal.

When Procedure Protects: How a Drug Case Hinged on Evidence Handling

The case of People of the Philippines v. Benjamin Feriol began with an informant’s tip that Feriol, known as “Allan,” was involved in illegal drug activities. Subsequently, a buy-bust operation was set up, leading to Feriol’s arrest and the seizure of a plastic sachet containing a white crystalline substance. The prosecution argued that this substance tested positive for methamphetamine hydrochloride, or shabu, a dangerous drug, and that Feriol was caught in the act of selling it. Feriol, however, denied these accusations, claiming he was wrongly apprehended. The central legal issue revolved around whether the prosecution had sufficiently established the identity and integrity of the seized drug, especially concerning adherence to the chain of custody rule mandated by law.

At the heart of this case lies Section 5, Article II of Republic Act No. 9165 (RA 9165), the “Comprehensive Dangerous Drugs Act of 2002,” which penalizes the illegal sale of dangerous drugs. To secure a conviction, the prosecution must prove beyond reasonable doubt the elements of the crime: the identities of the buyer and seller, the object of the sale (the dangerous drug), the consideration (payment), the delivery of the drug, and the payment made. Critical to establishing guilt is maintaining an unbroken chain of custody. This ensures the drug presented in court is the same one seized from the accused, thus preserving its integrity as evidence.

Section 21, Article II of RA 9165 outlines a strict procedure for handling seized drugs. Prior to its amendment by RA 10640, it required that immediately after seizure, authorities must conduct a physical inventory and photograph the seized items in the presence of the accused (or their representative), a media representative, a Department of Justice (DOJ) representative, and any elected public official. These individuals are required to sign the inventory, receiving a copy for documentation. The seized drugs must then be turned over to the Philippine National Police Crime Laboratory within 24 hours for examination. This process, as highlighted in People v. Mendoza, aims to prevent evidence tampering and ensure accountability.

Without the insulating presence of the representative from the media or the [DOJ], or any elected public official during the seizure and marking of the [seized drugs], the evils of switching, ‘planting’ or contamination of the evidence that had tainted the buy-busts conducted under the regime of [RA] 6425 (Dangerous Drugs Act of 1972) again reared their ugly heads as to negate the integrity and credibility of the seizure and confiscation of the [said drugs) that were evidence herein of the corpus delicti, and thus adversely affected the trustworthiness of the incrimination of the accused. Indeed, the x x x presence of such witnesses would have preserved an unbroken chain of custody.

However, the law recognizes that strict compliance may not always be feasible. The Implementing Rules and Regulations (IRR) of RA 9165, later reinforced by RA 10640, acknowledge that inventory and photography can occur at the nearest police station in warrantless seizure cases. Crucially, non-compliance with Section 21 does not automatically invalidate the seizure if the integrity and evidentiary value of the seized items are preserved. The prosecution must demonstrate justifiable grounds for non-compliance and prove the integrity of the evidence was maintained.

Non-compliance 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.

In People v. Almorfe, the Court emphasized that the prosecution bears the burden of explaining any procedural lapses and ensuring the evidence’s integrity remained intact. People v. De Guzman further clarified that justifiable grounds for non-compliance must be proven as a matter of fact, not presumed. The Supreme Court found the apprehending officers in Feriol’s case failed to justify their deviations from the chain of custody rule, casting doubt on the drug’s integrity.

While the inventory and photography occurred in Feriol’s presence and that of an elected public official, the record lacked evidence of attempts to secure representatives from the DOJ and the media. The officers provided no explanation for this omission. This failure, the Court reasoned, directly contravenes the requirements for maintaining the integrity and evidentiary value of the seized item. The Supreme Court has consistently held that these procedures are not mere technicalities. In People v. Miranda, the Court emphasized the state’s duty to account for any lapses in the chain of custody, regardless of whether the defense raises the issue.

Therefore, as the requirements are clearly set forth in the law, then the State retains the positive duty to account for any lapses in the chain of custody of the drugs/items seized from the accused, regardless of whether or not the defense raises the same in the proceedings a quo; otherwise, it risks the possibility of having a conviction overturned on grounds that go into the evidence’s integrity and evidentiary value, albeit the same are raised only for the first time on appeal, or even not raised, become apparent upon further review.

The Court has repeatedly reminded prosecutors of their duty to demonstrate compliance with Section 21, as amended, and to justify any deviations during trial. Compliance is fundamental to the integrity of the corpus delicti and the accused’s liberty. Without justifiable reasons for procedural lapses, appellate courts must acquit the accused, overturning any conviction. Due to the prosecution’s failure to provide valid reasons excusing their non-compliance, the Supreme Court acquitted Feriol. The Court found the integrity and evidentiary value of the alleged seized item were compromised, preventing a finding of guilt beyond a reasonable doubt.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution adequately established an unbroken chain of custody for the seized drugs, as required by RA 9165, ensuring the integrity and evidentiary value of the evidence.
What is the chain of custody rule?	The chain of custody rule refers to the process of documenting and tracking the handling of evidence, from its initial seizure to its presentation in court, to ensure its integrity and prevent tampering.
What are the requirements of Section 21 of RA 9165?	Section 21 requires immediate inventory and photography of seized drugs in the presence of the accused, a media representative, a DOJ representative, and an elected public official.
What happens if there is non-compliance with Section 21?	Non-compliance does not automatically invalidate the seizure if the prosecution can prove justifiable grounds for the deviation and that the integrity and evidentiary value of the seized items were preserved.
Who has the burden of proving compliance with Section 21?	The prosecution has the burden of proving compliance with Section 21 and must justify any deviations from the prescribed procedure.
What role do media and DOJ representatives play in drug cases?	The presence of media and DOJ representatives during the inventory and photography of seized drugs serves as a safeguard against evidence tampering or planting.
What was the court’s ruling in this case?	The Supreme Court acquitted Benjamin Feriol due to the prosecution’s failure to establish an unbroken chain of custody, compromising the integrity and evidentiary value of the seized drugs.
What is the significance of this ruling?	This ruling underscores the importance of strict adherence to procedural safeguards in drug cases to protect the rights of the accused and maintain the integrity of the judicial process.

The People v. Feriol case reinforces the necessity for law enforcement to meticulously follow the chain of custody rule in drug cases. The ruling emphasizes that the integrity of evidence is paramount, and any deviation from established protocols without justifiable explanation can lead to acquittal. This decision serves as a critical reminder of the importance of upholding due process and protecting the rights 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. Feriol, G.R. No. 232154, August 20, 2018