In the case of *People of the Philippines vs. Mark Vincent Corral y Batalla*, the Supreme Court acquitted the accused due to the prosecution’s failure to adhere strictly to the chain of custody rule in drug-related cases. The Court emphasized the necessity of having representatives from the media and the Department of Justice (DOJ) present during the inventory and photography of seized items. This decision underscores the importance of procedural safeguards to protect individuals from potential police abuse, reinforcing that non-compliance with these requirements can lead to an acquittal.

Buy-Bust Blues: When Missing Witnesses Lead to Freedom

The case revolves around Mark Vincent Corral y Batalla, who was apprehended during a buy-bust operation conducted by the Calamba City Police Station. The police officers alleged that they recovered a small plastic sachet containing 0.03 gram of white crystalline substance from Corral during the operation. Following the arrest, a further search allegedly yielded another plastic sachet containing 0.18 gram of a similar substance, along with drug paraphernalia. The inventory and photography of these seized items were conducted at the barangay hall, with only Barangay Captain Antonino P. Trinidad present as a witness.

At trial, the Regional Trial Court (RTC) found Corral guilty of Illegal Sale of Dangerous Drugs, sentencing him to life imprisonment and a fine of P500,000.00. However, the RTC acquitted him on charges of Illegal Possession of Dangerous Drugs and Drug Paraphernalia, citing the prosecution’s failure to prove his guilt beyond a reasonable doubt. Corral appealed his conviction to the Court of Appeals (CA), which affirmed the RTC’s decision. The CA ruled that there was substantial compliance with the chain of custody requirement, as the inventory and photography were witnessed by Corral and a barangay official. Dissatisfied, Corral elevated the case to the Supreme Court.

The Supreme Court’s analysis centered on the **chain of custody** rule, a crucial aspect of drug-related cases. The Court reiterated that the identity of the dangerous drug must be established with moral certainty, as it forms an integral part of the *corpus delicti* of the crime. This requires the prosecution to account for each link in the chain, from the moment the drugs are seized to their presentation in court as evidence. The law mandates that the marking, physical inventory, and photography of seized items be conducted immediately after seizure. Moreover, these procedures must be performed in the presence of the accused or their representative, as well as representatives from the media and the DOJ, along with an elected public official.

The purpose of these witness requirements, according to the Court, is to ensure the establishment of the chain of custody and to remove any suspicion of switching, planting, or contamination of evidence. While strict compliance with the chain of custody procedure is generally required, the Court acknowledged that varying field conditions may make this impossible. In such cases, the failure to strictly comply would not automatically render the seizure void, provided that the prosecution satisfactorily proves that there is a justifiable ground for non-compliance and that the integrity and evidentiary value of the seized items are properly preserved.

However, the Court emphasized that the prosecution must duly explain the reasons behind any procedural lapses. The justifiable ground for non-compliance must be proven as a fact, as the Court cannot presume its existence. Regarding the witness requirement, non-compliance may be excused if the prosecution proves that the apprehending officers exerted genuine and sufficient efforts to secure the presence of the required witnesses, even if they ultimately failed to appear. Mere statements of unavailability, without actual serious attempts to contact the witnesses, are insufficient to justify non-compliance.

In this case, the Supreme Court found that the prosecution failed to comply with the prescribed procedure, as the inventory and photography of the seized items were not conducted in the presence of representatives from the media and DOJ. The Receipt of Physical Inventory confirmed the presence of only an elected public official. Furthermore, the testimonies of the poseur-buyer and back-up officer acknowledged the absence of the required representatives, without providing any justification for their absence or demonstrating any efforts to contact them.

The Court referenced its reminder in *People v. Miranda*, emphasizing the State’s duty to account for any lapses in the chain of custody of seized drugs, regardless of whether the defense raises the issue. Failure to do so risks having a conviction overturned, even if the issue is raised for the first time on appeal. Due to the unjustified deviation from the chain of custody rule in Corral’s case, the Court concluded that the integrity and evidentiary value of the seized items were compromised. Consequently, the Court granted Corral’s appeal and acquitted him of the crime charged.

FAQs

What was the key issue in this case?	The key issue was whether the failure to have representatives from the media and DOJ present during the inventory and photography of seized drugs compromised the chain of custody, warranting an acquittal.
What is the chain of custody rule in drug cases?	The chain of custody rule requires that the prosecution account for each link in the chain, from the moment the drugs are seized to their presentation in court, ensuring the integrity and identity of the evidence.
Why is it important to have media and DOJ representatives present?	Their presence is intended to ensure transparency and prevent the switching, planting, or contamination of evidence, thus safeguarding the rights of the accused.
Can the absence of these witnesses be excused?	Yes, but only if the prosecution can provide a justifiable reason for their absence and demonstrate that genuine efforts were made to secure their presence.
What happens if the chain of custody is broken?	If the chain of custody is broken, the integrity and evidentiary value of the seized items are compromised, potentially leading to an acquittal of the accused.
Did the police follow proper procedure in this case?	No, the Supreme Court found that the police failed to justify the absence of the media and DOJ representatives during the inventory and photography of the seized items.
What was the Supreme Court’s ruling?	The Supreme Court reversed the Court of Appeals’ decision and acquitted Mark Vincent Corral y Batalla due to the compromised 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 individuals from potential police abuse and ensure a fair trial.

This case serves as a reminder of the critical importance of adhering to the chain of custody rule in drug-related cases. The presence of media and DOJ representatives is not a mere formality but a crucial safeguard to protect the rights of the accused and ensure the integrity of the evidence. The Supreme Court’s decision underscores that failure to comply with these requirements can have significant consequences, potentially leading to 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 of the Philippines vs. Mark Vincent Corral y Batalla, G.R. No. 233883, January 07, 2019