G.R. No. 254208, August 16, 2022
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. MA. DEL PILAR ROSARIO C. CASA, ACCUSED-APPELLANT.

FACTS

This case involves an appeal from a conviction for violations of the Comprehensive Dangerous Drugs Act. The prosecution’s evidence stemmed from a buy-bust operation where accused-appellant Ma. Del Pilar Rosario C. Casa was apprehended. The apprehending team conducted the physical inventory and photographing of the seized items not at the place of seizure but at the police station. The prosecution offered a general explanation for this deviation, citing alleged security concerns. Furthermore, the accused-appellant did not sign the inventory receipt, and there was a noted dearth of evidence regarding the management and storage of the illegal drugs while in the custody of the forensic chemist prior to their presentation in court.
The ponencia, penned by Chief Justice Gesmundo, acquitted the accused-appellant. The acquittal was anchored on the prosecution’s failure to prove the elements of the crimes beyond reasonable doubt and its non-compliance with the chain of custody requirements under Section 21 of Republic Act No. 9165, as amended. The decision particularly highlighted the unjustified failure to conduct the inventory and photography at the place of seizure, which compromised the integrity of the seized evidence.

ISSUE

Whether the prosecution’s failure to comply with the chain of custody rule, specifically the requirement to conduct the inventory and photography “immediately after seizure and confiscation,” warrants the acquittal of the accused-appellant.

RULING

Yes, the acquittal is proper. Justice Lopez, in her Concurring Opinion, agrees with the ponencia’s result but provides a focused analysis on the statutory interpretation of “immediately” within the chain of custody rule. She notes that while the ponencia acquitted based on multiple lapses, her concurrence emphasizes the critical failure regarding the immediacy of the inventory. The law, as amended by R.A. No. 10640, mandates that inventory and photography be done “immediately after seizure and confiscation.” The term “immediately” denotes prompt action without delay, though it is not an inflexible concept excluding any interval of time; it is a contextual determination based on the circumstances of each case.
Justice Lopez clarifies that the law permits the inventory to be conducted at the nearest police station in warrantless seizures if practicable, but this does not dispense with the requirement of immediacy. The transfer of the evidence to the station must itself be immediate and justified. In this case, the police’s general invocation of security concerns, without particularized details, failed to justify the delay and the change of venue. This lapse, coupled with other breaks in the chain such as the unsigned inventory and gaps in evidence custody, collectively eroded the integrity and evidentiary value of the seized items. Therefore, the prosecution failed to overcome the presumption of innocence, making acquittal the only legally sound outcome. The concurrence reinforces that strict compliance with procedural safeguards is essential to preserve the rights of the accused in drug-related prosecutions.