In the case of People of the Philippines vs. Michael Roxas y Camarillo, the Supreme Court acquitted the accused due to the prosecution’s failure to establish an unbroken chain of custody for the seized drugs. The absence of a Department of Justice (DOJ) representative during the inventory, without a justifiable explanation, compromised the integrity and evidentiary value of the seized item. This decision underscores the importance of strict adherence to procedural safeguards in drug cases to protect individual rights and ensure fair trials; the case highlights how deviations from the chain of custody rule can lead to the acquittal of the accused, even if the evidence seems incriminating.

Broken Chains: When Missing Witnesses Free the Accused

The case revolves around Michael Roxas y Camarillo, who was apprehended during a buy-bust operation for allegedly selling shabu. The prosecution presented evidence indicating that Roxas sold a plastic sachet containing methamphetamine hydrochloride to a poseur-buyer. However, critical procedural lapses in handling the evidence raised significant questions about the integrity of the seized drugs. This case highlights the critical importance of adhering to the strict chain of custody rule in drug-related cases. The Supreme Court meticulously examines whether the procedural requirements were met and, if not, whether such non-compliance could be excused.

The legal framework for drug cases in the Philippines is primarily governed by Republic Act No. 9165, also known as the “Comprehensive Dangerous Drugs Act of 2002.” This law outlines the procedures for handling drug-related evidence, emphasizing the need to maintain an unbroken chain of custody. The chain of custody refers to the sequence of transferring evidence from one person to another, from the time of seizure until its presentation in court. The rationale behind this requirement is to ensure that the integrity and evidentiary value of the seized items are preserved, preventing any possibility of tampering, substitution, or contamination.

Section 21 of RA 9165 and its Implementing Rules and Regulations (IRR) prescribe specific steps to be followed in handling seized drugs. These steps include the immediate marking of the seized items, conducting a physical inventory, and taking photographs. These actions must be performed immediately after seizure and confiscation. Moreover, the inventory and photography must be done in the presence of the accused or his representative, as well as certain mandatory witnesses. Prior to the amendment of RA 9165 by RA 10640, these witnesses included a representative from the media and the DOJ, along with any elected public official. After the amendment, the required witnesses are an elected public official and a representative of the National Prosecution Service (NPS) or the media.

In this case, the inventory of the seized item was conducted in the presence of a barangay captain and a media representative, but without a DOJ representative. The testimonies of the arresting officers confirmed this absence, and the prosecution failed to provide a justifiable reason for it. According to PO3 Dela Cruz’s testimony:

Q: Mr. Witness, it appears that there is no representative from the [DOJ]. Why is it that there was no representative from the DOJ?
A: Because nobody came from the [DOJ], sir.

Similarly, PO3 Almazan stated:

Q: And why is it there is no DOJ representative?
A: Because there was no available, sir.

The Supreme Court emphasized that the prosecution had a positive duty to account for the absence of the DOJ representative. The Court cited its previous ruling in People v. Miranda, reminding prosecutors to account for any lapses in the chain of custody, regardless of whether the defense raises the issue. The Court noted that 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 recognized that strict compliance with the chain of custody procedure is not always possible due to varying field conditions. However, non-compliance can be excused if the prosecution proves that there is a justifiable ground for the deviation and that the integrity and evidentiary value of the seized items are properly preserved. This is based on the saving clause in Section 21 (a), Article II of the IRR of RA 9165, which was later adopted into the text of RA 10640.

Provided, further, that non-compliance with 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 of and custody over said items.

The Court stressed that the prosecution must duly explain the reasons behind the procedural lapses. The justifiable ground for non-compliance must be proven as a fact, and the Court cannot presume what these grounds are or that they even exist. The Court clarified that mere statements of unavailability, absent actual serious attempts to contact the required witnesses, are unacceptable as justified grounds for non-compliance. This consideration stems from the fact that police officers are given sufficient time to prepare for a buy-bust operation and consequently, make the necessary arrangements beforehand.

Because the prosecution failed to inquire whether the arresting officers exerted earnest efforts in securing the presence of the DOJ representative, the Court concluded that the integrity and evidentiary value of the seized item were compromised. This unjustified deviation from the chain of custody rule warranted the acquittal of Roxas. The Court found that the prosecution did not present sufficient evidence to establish the integrity of the seized drugs, thus failing to prove Roxas’s guilt beyond a reasonable doubt.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution established an unbroken chain of custody for the seized drugs, particularly regarding the absence of a Department of Justice (DOJ) representative during the inventory.
What is the chain of custody rule?	The chain of custody rule refers to the sequence of transferring evidence from one person to another, from the time of seizure until its presentation in court, ensuring the integrity and evidentiary value of the seized items.
Why is the chain of custody rule important in drug cases?	It prevents any possibility of tampering, substitution, or contamination of the evidence, ensuring that the drugs presented in court are the same ones seized from the accused.
What are the required steps in the chain of custody under RA 9165?	The steps include immediate marking of the seized items, conducting a physical inventory, and taking photographs, all in the presence of the accused and certain mandatory witnesses.
Who are the mandatory witnesses required during the inventory?	Prior to RA 10640, the witnesses included a representative from the media and the DOJ, along with any elected public official. After the amendment, the required witnesses are an elected public official and a representative of the National Prosecution Service (NPS) or the media.
What happens if there is non-compliance with the chain of custody rule?	Non-compliance can be excused if the prosecution proves that there is a justifiable ground for the deviation and that the integrity and evidentiary value of the seized items are properly preserved.
What constitutes a justifiable ground for non-compliance?	The prosecution must provide a valid reason for the absence of a required witness and show that genuine and sufficient efforts were made to secure their presence.
What was the Court’s ruling in this case?	The Court acquitted the accused due to the prosecution’s failure to justify the absence of a DOJ representative during the inventory, compromising the integrity of the evidence.
What is the significance of the People v. Miranda case in this context?	The Miranda case emphasizes the prosecution’s duty to account for any lapses in the chain of custody, regardless of whether the defense raises the issue.

This case serves as a reminder of the stringent requirements for handling drug-related evidence and the importance of adhering to the chain of custody rule. It underscores that procedural safeguards are essential to protect individual rights and ensure fair trials. Failure to comply with these safeguards can result in the acquittal of the accused, regardless of the apparent strength of the evidence.

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. ROXAS, G.R. No. 242817, September 16, 2019