In People v. Manabat, the Supreme Court acquitted the accused due to the prosecution’s failure to adhere strictly to the procedural requirements outlined in Section 21 of Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002. The Court emphasized that the integrity of the chain of custody for seized drugs must be meticulously maintained to uphold the accused’s constitutional right to be presumed innocent. This decision underscores the necessity for law enforcement to rigorously follow protocol in drug-related arrests to ensure that evidence is not compromised, thus protecting individual liberties against potential abuse in anti-narcotics operations.

When Procedure Protects: How a Buy-Bust Operation Failed to Secure a Conviction

The case revolves around the arrest and conviction of Mario Manabat for the illegal sale and possession of dangerous drugs. Following a buy-bust operation, Manabat was found guilty by the Regional Trial Court (RTC) and the Court of Appeals (CA). However, the Supreme Court overturned these decisions, citing significant lapses in the conduct of the operation and the handling of evidence. The core issue was whether the procedural requirements for handling seized drugs, as mandated by law, were sufficiently met to ensure the integrity of the evidence presented against Manabat.

The Supreme Court anchored its decision on the importance of adhering to Section 21, Article II of RA 9165, which outlines the specific steps law enforcement must take to maintain the integrity of seized drugs. This provision mandates that seized items must be inventoried and photographed immediately after seizure, in the presence of the accused, an elected public official, a representative from the media, and a representative from the Department of Justice (DOJ). All these individuals are required to sign the inventory and receive a copy, ensuring transparency and accountability.

The Court found several critical flaws in the prosecution’s case. First, the required witnesses were not present at the time of the arrest.

The presence of the witnesses from the DO J, media, and from public elective office is necessary to protect against the possibility of planting, contamination, or loss of the seized drug.

PO2 Barral admitted that the witnesses arrived after the accused was already apprehended. This delay violated the requirement that the inventory and photographing be done immediately after seizure. The purpose of having these witnesses present is to ensure transparency and prevent any potential for evidence tampering, a crucial safeguard in drug cases.

Further complicating matters, the Certificate of Inventory lacked the signature of the accused, Mario Manabat, or his legal representative. While the Implementing Rules and Regulations (IRR) of RA 9165 allow for noncompliance under justifiable grounds, the prosecution failed to acknowledge this lapse or provide any explanation for it. This omission was a significant blow to the prosecution’s case, as it raised doubts about the fairness and integrity of the inventory process.

Adding to the procedural missteps, the marking of the seized plastic sachets was also found to be irregular.

The seizing officer (normally the poseur-buyer) and the evidence custodian must mark the evidence with their initials and also indicate the date, time and place the evidence was confiscated/seized.

The specimens only contained the date and initials of the seizing officers, but notably missing was the time and place of the confiscation, a clear violation of the Philippine National Police Drug Enforcement Manual’s guidelines for conducting buy-bust operations. Such omissions can lead to questions about the evidence’s origin and handling, further undermining the prosecution’s case.

The Supreme Court highlighted a critical misunderstanding by the lower courts regarding the presumption of innocence. While the RTC and CA dismissed Manabat’s defense of denial as inherently weak, they overlooked the fundamental principle that the accused is presumed innocent until proven guilty beyond a reasonable doubt. This presumption places the burden squarely on the prosecution to prove each element of the crime, and it never shifts to the accused.

The Court emphasized that in cases involving dangerous drugs, the prosecution bears the burden of proving compliance with the procedures outlined in Section 21. If the prosecution fails to adequately demonstrate that these procedures were followed, the accused is entitled to an acquittal. The prosecution’s failure to justify the police officers’ deviation from the required procedures compromised the integrity and evidentiary value of the corpus delicti, the body of the crime.

Moreover, the Court rejected the lower courts’ reliance on the presumption of regularity in the performance of duties by the police officers. The presumption of regularity cannot override the stronger presumption of innocence in favor of the accused. In this case, the buy-bust team’s disregard for the established procedures under Section 21 of RA 9165 and the PNP’s Drug Enforcement Manual invalidated any presumption of regularity.

The Supreme Court’s decision in People v. Manabat serves as a powerful reminder of the importance of due process and strict adherence to legal procedures in drug cases. The ruling emphasizes that the rights of the accused must be protected, and any deviation from established protocols must be justified to ensure the integrity of the evidence presented. This case reinforces the principle that in the pursuit of justice, procedural safeguards cannot be sacrificed, especially when an individual’s liberty is at stake.

FAQs

What was the key issue in this case?	The key issue was whether the police complied with the chain of custody requirements under Section 21 of RA 9165 when handling the seized drugs. The Supreme Court found significant lapses in the procedure.
Why was the accused acquitted in this case?	The accused was acquitted because the prosecution failed to prove his guilt beyond a reasonable doubt. This failure stemmed from non-compliance with mandatory procedures for handling drug evidence.
What is the importance of Section 21 of RA 9165?	Section 21 of RA 9165 outlines the procedures that law enforcement must follow to maintain the integrity of seized drugs, from the point of seizure to their presentation in court. Compliance with this section is essential to ensure the reliability of evidence in drug-related cases.
What are the roles of the witnesses required during the inventory?	The presence of representatives from the media, the DOJ, and an elected public official aims to prevent planting, contamination, or loss of the seized drug. Their presence ensures transparency and accountability in the handling of drug evidence.
What happens if the chain of custody is compromised?	If the chain of custody is compromised, the integrity and evidentiary value of the seized drugs are put into question. This can lead to the acquittal of the accused due to reasonable doubt.
Can the presumption of regularity override the presumption of innocence?	No, the presumption of regularity in the performance of duty by law enforcement cannot override the stronger presumption of innocence in favor of the accused. The burden is always on the prosecution to prove guilt beyond a reasonable doubt.
What is the significance of marking the seized drugs?	Marking the seized drugs with the initials of the seizing officer, the date, time, and place of confiscation is essential for identification and tracking. This helps ensure that the evidence presented in court is the same evidence that was seized from the accused.
What is the “corpus delicti” in drug cases?	In drug cases, the “corpus delicti” refers to the actual dangerous drug itself. It is the body of the crime and must be proven beyond a reasonable doubt for a conviction to stand.

The Supreme Court’s decision in People v. Manabat underscores the judiciary’s commitment to protecting individual rights and ensuring due process, especially in drug-related cases. This ruling serves as a stern warning to law enforcement agencies to strictly adhere to the procedural requirements outlined in RA 9165, ensuring that the integrity of evidence is maintained and the rights of the accused are protected.

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. Mario Manabat y Dumagay, G.R. No. 242947, July 17, 2019