CASE DIGEST
Reyes, Jr. y De Los
Reyes v. People
G.R. No. 244545 (Resolution), [February 10,
2021]
SECOND, LOPEZ, M.V
Drug cases; Chain of Custody Rule; Required Witness during inventory and markings
The constitutional right of the accused
to be presumed innocent until proven guilty beyond reasonable doubt cannot be
overridden by the presumption of regularity in the performance of duties by law
enforcement.
The Laoag City Police Station conducted
a buy-bust operation targeting Franklin Reyes (Reyes), based on information
from a police asset. During the operation, PO1 Irving Lorenzo acted as the
poseur-buyer, and PO1 Jay Joemar Corpuz and other officers provided backup.
Reyes was accused of selling and possessing methamphetamine hydrochloride
(shabu). The police asset arranged a drug transaction, and when Reyes handed
over the drugs to PO1 Lorenzo, a pre-arranged signal was given, leading to
Reyes' arrest. During the inventory and photographing of seized items, there
was a notable absence of an insulating witness from the National Prosecution
Service or the media. The police conducted an inventory of the seized items in
the presence of Barangay Kagawad Helen Bulaun only. Reyes denied the
accusations, claiming he was alone in his apartment, and alleged that the
police arrested him, beat him, and planted the drugs.
Whether or not the prosecution
established the guilt of Reyes beyond reasonable doubt for the illegal sale and
possession of dangerous drugs.
NO.
The Supreme Court reversed the Court of Appeals' decision, acquitting Reyes of
the charges. The Court found a broken chain of custody, emphasizing the absence
of an insulating witness during the inventory and photographing of the seized
items. The chain of custody must be established to ensure the integrity and
admissibility of seized drugs as evidence. It involves marking, turnover, and
documentation at each stage, with the presence of insulating witnesses. The
Court stressed that the presence of insulating witnesses is crucial to ensuring
the integrity of the seized drugs. The absence of a representative of the
National Prosecution Service or the media as an insulating witness to the
inventory and photograph of the seized item puts serious doubt as to the
integrity of the first link. Since the prosecution failed to provide a
justifiable reason for the absence of the required witnesses and did not show
earnest efforts to secure their attendance, the chain of custody was
compromised. Law enforcers must strictly comply with prescribed procedures in
drug-related operations, and any deviation may compromise the admissibility of
seized items.
Also, the Court also highlighted the presumption of
innocence, which cannot be overridden by the presumption of regularity in the
performance of duties by law enforcers. Due to the lapses in handling the
evidence, Reyes was acquitted, and the decision ordered his immediate release
from detention.
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