People v. Lacdan
REITERATIONFacts
The Antecedents: On March 2, 2013, PO2 Alexander Gallega received information regarding appellant Shager Lacdan's involvement in illegal drug activities. After surveillance confirmed the report, a buy-bust team was formed. On March 3, 2013, at approximately 12:40 AM, the team proceeded to the location. PO2 Gallega, acting as poseur-buyer, met appellant outside his residence. Following the introduction by a confidential informant, PO2 Gallega purchased one plastic sachet of suspected shabu from appellant. Upon signal, the team apprehended appellant, recovered the buy-bust money, and seized the sachet, which was marked "SL-B". The team proceeded to the police station where an inventory and photograph of the seized items were conducted in the presence of a media representative. The sachet was then brought to the crime laboratory for examination. Procedural History: The Forensic Chemist confirmed the sachet contained methamphetamine hydrochloride. The Regional Trial Court (RTC) found appellant guilty of violation of Section 5, Article II of Republic Act 9165 (RA 9165), sentencing him to life imprisonment and a fine of P500,000.00. The Court of Appeals (CA) affirmed the conviction. Appellant appealed to the Supreme Court. The Petition: Appellant argued that the prosecution failed to prove the identity and integrity of the seized drugs due to non-compliance with the chain of custody rule, specifically the absence of required witnesses during the inventory and photograph, and the lack of his signature on the certificate of inventory.
Issue(s)
Whether the prosecution sufficiently established an unbroken chain of custody of the seized illegal drug, considering the procedural requirements under Section 21 of RA 9165. Whether the non-compliance with the procedural requirements under Section 21 of RA 9165, specifically the absence of required witnesses during inventory and photograph, and gaps in the chain of custody, renders the seizure void, thereby warranting acquittal.
Ruling
The appeal is GRANTED. The Decision of the Court of Appeals is REVERSED AND SET ASIDE. Appellant Shager Lacdan y Parto is ACQUITTED of violation of Section 5, Article II of Republic Act 9165. The Director of the Bureau of Corrections is directed to release appellant from custody unless held for other lawful cause.
Ratio Decidendi
On the issue of the chain of custody rule and compliance with Section 21 of RA 9165: The Supreme Court held that the prosecution failed to establish an unbroken chain of custody over the seized illegal drug, thereby casting serious doubt on its identity and integrity. The Court meticulously examined each link of the chain. Regarding the first link (seizure and marking), the Court noted that while the marking was done at the place of incident, the physical inventory and photograph were conducted at the police station with only a media representative present, lacking a Department of Justice (DOJ) representative and an elected public official, contrary to the requirements of Section 21 of RA 9165. The Court cited People v. Seguiente and People v. Rojas where similar deficiencies led to acquittal. The Court emphasized that the prosecution failed to explain the absence of these required witnesses. On the issue of the effect of non-compliance with Section 21 of RA 9165 and the broken chain of custody: The Court found a breach in the second link, as there was no testimony detailing the turnover of the seized item from the apprehending officer to an investigating officer. The Court also identified a deficiency in the third link, where PO2 Gallega handed the sachet to an unnamed and unpresented receiving clerk at the crime laboratory, with no proof of how it was handled until it reached the forensic chemist. Lastly, the fourth link was also found wanting, as the handling and storage of the seized item by the evidence custodian after examination, before its presentation in court, were not shown. The Court reiterated the pronouncement in Mallillin v. People that testimony about every link in the chain, including how the item was handled, its condition, and precautions taken to prevent tampering, is necessary for authentication. The Court concluded that these multiple violations of the chain of custody rule rendered the corpus delicti uncertain, warranting acquittal.
Main Doctrine
The prosecution must establish an unbroken chain of custody over the seized illegal drugs to preserve their integrity and evidentiary value. Non-compliance with the procedural safeguards, such as the presence of required witnesses during inventory and photograph, without justifiable grounds, casts serious doubt on the corpus delicti, warranting acquittal.