In People of the Philippines vs. Edwin Labadan and Raquel Sagum, the Supreme Court acquitted the accused due to critical gaps in the chain of custody of the seized drugs and non-compliance with witness requirements. The Court emphasized that for drug-related convictions, the prosecution must meticulously prove an unbroken chain of custody from seizure to presentation in court. This case underscores the importance of strict adherence to procedures outlined in Republic Act No. 9165, ensuring the integrity and evidentiary value of drug evidence are preserved, thereby protecting the constitutional rights of the accused. This ruling highlights the judiciary’s commitment to upholding due process and ensuring that convictions are based on reliable and untainted evidence.

Flawed Evidence: Did a Broken Chain of Custody Free Accused Drug Dealers?

The case began with a buy-bust operation conducted by police officers based on information from a confidential informant. Edwin Labadan and Raquel Sagum were arrested for allegedly selling methamphetamine hydrochloride, commonly known as “shabu.” The prosecution presented testimonies from PO3 Joel Diomampo and PO3 Napoleon Zamora, who were part of the buy-bust team. They claimed that PO3 Diomampo acted as the poseur-buyer, purchasing the illegal drugs from the accused-appellants. After the arrest, the police officers marked the seized drugs, conducted an inventory at the barangay hall, and eventually submitted the specimen for laboratory examination. However, critical gaps in the chain of custody and deviations from the prescribed procedures led to the Supreme Court overturning the lower courts’ guilty verdict.

A central issue in this case was the prosecution’s failure to establish an unbroken chain of custody, as required by Section 21 of Republic Act No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002. This law outlines the procedures for handling seized drugs to ensure their integrity and evidentiary value. Section 21, as amended by R.A. No. 10640, provides specific guidelines on the custody and disposition of confiscated drugs:

SECTION 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 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;

The chain of custody, as defined by the Supreme Court, requires a clear and continuous narrative of who had custody of the confiscated drug, from the moment of seizure to the time it is presented as evidence in court. This involves detailing how each person received the item, where it was kept, what happened to it while in their possession, its condition upon receipt, and its condition upon delivery to the next person in the chain. Crucially, each witness must describe the precautions taken to ensure the item remained unaltered and inaccessible to those not in the chain.

In this case, the Court identified significant breaks in the chain of custody. Although PO3 Diomampo marked the sachet of shabu upon arrest and initially turned it over to SPO2 Abad, the specimen was then returned to PO3 Diomampo before being handed over to the forensic chemist, PCI Julian. This created an unexplained gap of almost two hours, raising questions about the specimen’s integrity during that period. Furthermore, after PCI Julian examined the sample, the prosecution failed to provide details about what happened to the specimen. The identity of the evidence custodian was not revealed, and no one testified regarding the handling and safekeeping of the drug sample after the examination. The Court emphasized that these missing details left the evidentiary value of the drugs in doubt, as it could not be said with certainty that the drugs were never compromised or tampered with.

Moreover, the Court found that the police officers failed to comply with the witness requirements outlined in Section 21 of R.A. No. 9165. The marking and inventory of the seized items were conducted only in the presence of a barangay kagawad, whereas the law requires the presence of an elected public official and a representative of the National Prosecution Service or the media. While the police officers claimed they made efforts to secure the presence of these witnesses, the Court deemed their explanation insufficient, as they failed to demonstrate actual serious attempts to contact the required witnesses. The Court cited previous rulings, such as People of the Philippines v. Alvarado, where it refused to overlook the absence of DOJ and media representatives, emphasizing that their presence can be ensured in planned operations like buy-busts.

The Supreme Court stressed that noncompliance with the witness requirements is permissible only under justifiable grounds, provided that the integrity and evidentiary value of the seized items are properly preserved. However, in this case, the prosecution failed to establish such justifiable circumstances. The mere assertion that no representatives were available was deemed unacceptable, especially given that the police officers had sufficient time to prepare for the buy-bust operation. The Court reiterated that police officers must convince the Court that they exerted earnest efforts to comply with the mandated procedure and that their actions were reasonable under the circumstances.

In light of these procedural lapses and evidentiary gaps, the Supreme Court overturned the lower courts’ conviction of Edwin Labadan and Raquel Sagum. The Court emphasized that the presumption of regularity in the performance of official duty is inferior to the constitutional presumption of innocence. Given the procedural irregularities in handling the seized shabu and the lack of evidence ensuring the drug sample was not tampered with, the Court ruled that a cloud of doubt surrounded the conviction, necessitating the accused-appellants’ acquittal.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution successfully established an unbroken chain of custody for the seized drugs and complied with the witness requirements outlined in Section 21 of R.A. No. 9165.
What is the chain of custody?	The chain of custody refers to the chronological documentation or paper trail that records the sequence of custody, control, transfer, analysis, and disposition of physical or electronic evidence. This ensures the integrity and reliability of the evidence presented in court.
What are the requirements for witnesses during the inventory of seized drugs?	Section 21 of R.A. No. 9165 requires the presence of an elected public official and a representative of the National Prosecution Service or the media during the physical inventory and photographing of seized drugs.
What happens if the police officers fail to comply with the witness requirements?	Noncompliance with the witness requirements may be excused under justifiable grounds, provided that the prosecution can demonstrate that the integrity and evidentiary value of the seized items were properly preserved.
What was the Supreme Court’s ruling in this case?	The Supreme Court reversed the lower courts’ conviction of Edwin Labadan and Raquel Sagum, acquitting them of the crime charged due to critical gaps in the chain of custody and non-compliance with witness requirements.
Why did the Supreme Court acquit the accused?	The Court acquitted the accused because the prosecution failed to establish an unbroken chain of custody for the seized drugs and did not adequately explain the absence of required witnesses during the inventory. This raised doubts about the integrity and reliability of the evidence.
What is the significance of this ruling?	This ruling underscores the importance of strict adherence to procedures outlined in R.A. No. 9165 to ensure the integrity and evidentiary value of drug evidence, thereby protecting the constitutional rights of the accused.
What does the prosecution need to prove in drug-related cases?	In drug-related cases, the prosecution must prove the identity of the buyer and seller, the object, and the consideration, as well as the delivery of the thing sold and the payment. It must also establish the drug’s identity through an unbroken chain of custody.

This case serves as a critical reminder to law enforcement agencies about the importance of adhering to the procedural safeguards outlined in R.A. No. 9165. The Supreme Court’s decision highlights the necessity of meticulous documentation and strict compliance with the chain of custody rule to ensure the reliability and admissibility of drug evidence in court. Failure to do so can result in the acquittal of the accused, regardless of the apparent strength of the case. This ruling reinforces the judiciary’s commitment to upholding due process and protecting the constitutional rights of individuals facing drug-related charges.

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 vs. Labadan, G.R. No. 237769, March 11, 2019