Calahi vs. People (2017)

ARNEL CALAHI ET. AL. vs. PEOPLE OF THE PHILIPPINES

G.R. No. 195043, November 20, 2017

MARTIRES, J.:

Facts: While serving the search warrant on Elsie Valenzuela, the CIDG members noticed an XLT jeep parked near Elsie's house. Suspicious, they approached said jeep and saw four (4) persons holding a pot session inside. They noticed the following items inside the vehicle: an aluminum foil, an improvised tooter, a lighter, and remnants of shabu. SPO3 Padilla and his team immediately arrested the four who were later identified as Enrique, Arnel, Nicasio, and Nicolas and confiscated the white substance found with them. Then they were brought to the police station in Cabanatuan City. Thereafter, SPO3 Padilla requested a laboratory examination on the confiscated substance by the PNP Crime Laboratory, Cabanatuan City. An Information charged petitioners for violation of the Dangerous Drugs Law.

Petitioner posits that the integrity and identity of the seized items were tarnished because the arresting officers failed to inventory and photograph the seized items in petitioners' presence.

Issue: Whether or not the petitioners' guilt has been proven beyond reasonable doubt.

Ruling: No. The prosecution failed to establish that the shabu was marked upon seizure.

The chain of custody rule requires proof of every link in the chain, from the moment the item was seized to the time it is presented in court and offered into evidence, such that witnesses constituting the chain are able to testify on how it was given and received, including the precautions taken to ensure that the seized item was not altered or tampered with.

In this case, the facts only establishes that after seizure of the items and arrest of the petitioners, the apprehending team took the latter to the police station, then requested a laboratory examination of the confiscated items, and eventually requested inquest proceedings in connection with the petitioners' arrest. It was not in any way established that the items were marked after seizure. While it appears that the specimen presented in court were marked with the initials, it was not shown who marked the same and when it was done, and whether it was done by the apprehending team upon seizure and before submission to the crime laboratory for examination or not.

Ratio Decidendi: The gap in the chain of custody caused by the lack of marking upon confiscation undermined the identity and integrity of the confiscated drug.

Gist: This appeal seeks to reverse the Decision of the CA which affirmed the Decision of the RTC, finding petitioners guilty beyond reasonable doubt of illegal use of dangerous drugs.