Title
Supreme Court
People vs. Dela Cruz
Case
G.R. No. 229053
Decision Date
Jul 17, 2019
Jordan Dela Cruz acquitted by Supreme Court due to prosecution's failure to comply with chain of custody requirements under RA 9165, undermining evidence integrity.

Case Digest (G.R. No. 67803-04)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • The case involves Jordan Casaclang Dela Cruz, a 20-year-old high school student, charged with violating Republic Act No. 9165 (the Comprehensive Dangerous Drugs Act of 2002) by allegedly engaging in the illegal sale and possession of dangerous drugs (specifically marijuana).
    • Two separate Informations were filed on July 23, 2012:
      • Criminal Case No. L-9497 charged Dela Cruz with illegal possession of marijuana (Section 11, Article II), alleging that he unlawfully had in his possession two plastic sachets containing a total of 2.8 grams of dried marijuana leaves.
      • Criminal Case No. L-9498 charged him with the illegal sale of the same drug (Section 5, Article II), alleging that he sold two plastic sachets of marijuana during a buy-bust operation.
  • The Buy-Bust Operation and Arrest
    • On July 10, 2012, at around 2:25 p.m., a team from the Lingayen Police Station began planning a buy-bust operation following surveillance of Dela Cruz.
    • The team, led by designated police officers including PO1 Jethiel F. Vidal, PO1 Santillan, and others, executed the operation as follows:
      • PO1 Santillan marked specific bills and conducted surveillance, which led him to recognize Dela Cruz.
      • At approximately 3:20 p.m., Dela Cruz was intercepted at a prearranged location near the Pangasinan National High School.
      • A transaction took place in which Dela Cruz exchanged two plastic sachets containing suspected marijuana for marked P50.00 bills.
      • During and immediately after the transaction, additional sachets were recovered from Dela Cruz. PO1 Santillan noted the markings on these items, and the police secured the seized drugs.
      • The apprehending team subsequently arrested Dela Cruz, and the seized items were later turned over to the Philippine National Police Crime Laboratory for forensic examination.
  • Evidentiary Proceedings
    • The prosecution presented five police witnesses who testified on various aspects:
      • The identification of Dela Cruz based on prior surveillance.
      • The conduct of the buy-bust operation, the seizure of the drugs, and the marking of the evidence.
    • The forensic laboratory, through a chemistry report, confirmed that the sealed sachets contained marijuana with varying weights ranging from 1.3 to 1.5 grams.
  • Defense and Trial Developments
    • At arraignment, Dela Cruz pleaded not guilty, denying knowledge of any involvement in the alleged illegal sale or possession of drugs.
    • In his defense, he claimed:
      • He was attending classes during the morning of the incident.
      • During lunch break, he was approached by unidentified men who coerced him into boarding a motorcycle, and he was then taken to the police station where he was interrogated.
      • He later testified that the men involved in his apprehension were not the same persons later identified by the police.
    • The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and imposed:
      • An indeterminate sentence for illegal possession.
      • A life imprisonment sentence for illegal sale, along with respective fines.
    • The Court of Appeals (CA) affirmed the RTC’s decision on October 5, 2016, though with a modification in the penalty for the possession charge.
  • Chain of Custody and Procedural Lapses
    • A significant point in the trial revolved around the handling of the seized evidence:
      • Section 21 of RA 9165 requires that, immediately after seizure, the evidence must be inventoried and photographed in the presence of:
        • The accused (or his representative or counsel),
        • An elected public official, and
        • A representative of the National Prosecution Service or the media.
      • In this case, none of the three prescribed parties was present during the physical inventory and photographing of the seized items.
    • The prosecution argued that despite these omissions, there was substantial compliance:
      • They pointed to the marking of bills and the seizure process.
      • They reasoned that the absence of the required witnesses was due to time constraints and Dela Cruz’s refusal to sign the inventory.
    • The defense contended that the failure to comply with the chain of custody protocols undermined the integrity of the evidence and, consequently, the proof of the corpus delicti.
  • Procedural History on Appeal
    • Dela Cruz filed a Notice of Appeal after the CA decision.
    • The appellate proceedings involved supplemental briefs and resolutions, with both the accused and the Office of the Solicitor General (representing the People) clarifying their positions.
    • The Supreme Court was then called to resolve whether the noncompliance with the chain of custody requirements forfeited the presumption of regularity and thus warranted the acquittal of Dela Cruz.

Issues:

  • Compliance with Chain of Custody Requirements
    • Whether the failure to secure the presence of all the third-party witnesses mandated by Section 21 of RA 9165 (i.e., the elected public official, and a representative of the National Prosecution Service or the media) during the physical inventory and photographing of the seized drugs affected the integrity of the evidence.
    • Whether the noncompliance, despite alleged justifiable grounds (time constraints and the accused’s refusal to sign), is sufficient to establish a gap in the chain of custody capable of nullifying the prosecution’s evidence.
  • Impact on the Proof Beyond Reasonable Doubt
    • Whether the lapse in chain-of-custody procedures creates a persistent doubt regarding the identity and integrity of the seized drug, thereby failing to meet the constitutional requirement of proving the accused’s guilt beyond reasonable doubt.
    • Whether the presumption of regularity in the performance of official duties can still be invoked in light of such procedural lapses.
  • Invocation of the Constitutional Presumption of Innocence
    • Whether the procedural lapses, in combination with the controversy over the identity of the evidence, necessitate the application of the constitutional presumption of innocence in determining the accused’s guilt.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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