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PEOPLE v. DARWIN RELATO Y AJERO

This case has been cited 9 times or more.

2016-01-11
DEL CASTILLO, J.
"Statutory rules on preserving the chain of custody of confiscated prohibited drugs and related items are designed to ensure the integrity and reliability of the evidence to be presented against the accused. Their observance is the key to the successful prosecution of illegal possession or. illegal sale of dangerous drugs."[1]
2015-03-11
BERSAMIN, J.
There is no question that the State had the responsibility to explain the lapses in the procedures taken to preserve the chain of custody of the dangerous drugs. Without the explanation by the State, the evidence of the corpus delicti became unreliable, and the acquittal of the accused should follow on the ground that his guilt had not been shown beyond reasonable doubt.[29] Absent the justification by the arresting lawmen for their non-compliance with the requirement of an intact chain of custody, the trial court and the CA did not fairly convict the appellant in whose favor the safeguards have been erected by the law. As the Court well stated in People v. Relato:[30]
2014-04-02
REYES, J.
These "[s]tatutory rules on preserving the chain of custody of confiscated prohibited drugs and related items are designed to ensure the integrity and reliability of the evidence to be presented against the accused. Their observance is the key to the successful prosecution of illegal possession or illegal sale of prohibited drugs."[21]
2013-12-11
ABAD, J.
One. When prosecuting the sale or possession of dangerous drugs like shabu, the State must prove not only the elements of each of the offenses. It must prove as well the corpus delicti, failing in which the State will be unable to discharge its basic duty of proving the guilt of the accused beyond reasonable doubt.[9]
2013-04-03
BERSAMIN, J.
By way of exception, Republic Act No. 9165 and its IRR both state that the non-compliance with the procedures thereby delineated and set would not necessarily invalidate the seizure and custody of the dangerous drugs provided there were justifiable grounds for the non-compliance, and provided that the integrity of the evidence of the corpus delicti was preserved. But the non-compliance with the procedures, to be excusable, must have to be justified by the State's agents themselves. Considering that PO1 Dimla tendered no justification in court for the non-compliance with the procedures, the exception did not apply herein. The absolution of Gonzales should then follow,[25] for we cannot deny that the observance of the chain of custody as defined by the law was the only assurance to him that his incrimination for the very serious crime had been legitimate and insulated from either invention or malice. In this connection, the Court states that the unexplained non-compliance with the procedures for preserving the chain of custody of the dangerous drugs has frequently caused the Court to absolve those found guilty by the lower courts.[26]
2013-02-27
PEREZ, J.
Obviously the steps outlined in Section 21(a), Article II of the Implementing Rules and Regulations of RA 9165 to ensure the integrity and evidentiary value of the evidence of corpus delicti were not followed.  That being the case,  it is necessary for the prosecution to show that inspite of the non-observance of the requirements in Section 21(a), Article II of the Implementing Rules and Regulations of RA 9165, the integrity and evidentiary value of the seized items were nonetheless preserved.  This was not done in this case.  The prosecution failed to show how SPO1 Pamor ensured the integrity of the seized items from the time it was entrusted to him at the place of confiscation until the team reached the police station[38] until he eventually handed them over again to PO2 Lagmay for the marking of the sachets.  Neither did the prosecution show to whom the confiscated articles were turned over and the manner they were preserved after the laboratory examination and until their final presentation in court as evidence of the corpus delicti.[39] Clearly, these lapses raise doubt on the integrity and identity of the drugs presented as evidence in court.[40]
2012-04-25
SERENO, J.
In a prosecution of the sale and possession of methamphetamine hydrochloride prohibited under Republic Act No. 9165, the State not only carries the heavy burden of proving the elements of the offense of, but also bears the obligation to prove the corpus delicti, failing in which the State will not discharge its basic duty of proving the guilt of the accused beyond reasonable doubt. It is settled that the State does not establish the corpus delicti when the prohibited substance subject of the prosecution is missing or when substantial gaps in the chain of custody of the prohibited substance raise grave doubts about the authenticity of the prohibited substance presented as evidence in court. Any gap renders the case for the State less than complete in terms of proving the guilt of the accused beyond reasonable doubt. Thus, Relato deserves exculpation, especially as we recall that his defense of frame-up became plausible in the face of the weakness of the Prosecution's evidence of guilt.[18] (Emphasis supplied and citations omitted.)