Lawyerly

You're currently signed in as:
User

PEOPLE v. EMILY MENDOZA Y SARTIN

This case has been cited 9 times or more.

	GR No. 198450 2016-01-11	PEOPLE v. FERNANDO RANCHE HAVANA DEL CASTILLO, J.
"[W]hile the chain of custody should ideally be perfect [and unbroken], in reality it is not, 'as it is almost always impossible to obtain an unbroken chain.'"[23] As such, what is of utmost importance "is the preservation of the integrity and the evidentiary value of the seized items as they will be used to determine the guilt or innocence of the accused."[24] In the case at bench, this Court finds it exceedingly difficult to believe that the integrity and evidentiary value of the drug have been properly preserved by the apprehending officers. The inexplicable failure of the police officers to testify as to what they did with the alleged drug while in their respective possession resulted in a breach or break in the chain of custody of the drug. In some cases,[25] the Court declared that the failure of the prosecution to offer the testimony of key witnesses to establish a sufficiently complete chain of custody of the shabu plus the irregular manner which plagued the handling of the evidence before the same was offered in court, whittles down the chances of the government to obtain a successful prosecution in a drug-related case.
	GR No. 189296 2015-03-11	PEOPLE v. RECTO ANGNGAO Y MAKAY BERSAMIN, J.
The Court accepts that "while the chain of custody should ideally be perfect, in reality it is not, 'as it is almost always impossible to obtain an unbroken chain.'"[17] This limitation on the chain of custody is well recognized in Section 21 of R.A. No. 9165's IRR, which states that non-compliance with the rules' requirements under justifiable grounds shall not render void and invalid such seizures of and custody over said items as long as the integrity and evidentiary value of the seized items are properly preserved by the apprehending officer/team. In resolving drug-related offenses, therefore, the courts should deem to be essential "the preservation of the integrity and the evidentiary value of the seized items, as the same would be utilized in the determination of the guilt or innocence of the accused."[18]
	GR No. 205741 2014-07-23	PEOPLE v. REYMAN ENDAYA Y LAIG PEREZ, J.
Indeed, this Court has, in many cases held that "while the chain of custody should ideally be perfect, in reality it is not, 'as it is almost always impossible to obtain an unbroken chain. The most important factor is the preservation of the integrity and the evidentiary value of the seized items as they will be used to determine the guilt or innocence of the accused."[46]
	GR No. 206770 2014-04-02	PEOPLE v. NOEL PRAJES REYES, J.
In a line of cases, the Court has nonetheless explained that "while the chain of custody should ideally be perfect, in reality it is not, 'as it is almost always impossible to obtain an unbroken chain.'"[22] The limitation on chain of custody is also recognized in the afore-quoted Section 21 of R.A. No. 9165's IRR, as it states that non-compliance with the rules' requirements under justifiable grounds, as long as the integrity and evidentiary value of the seized items are properly preserved by the apprehending officer/team, shall not render void and invalid such seizures of and custody over said items. In resolving drug cases, we then repeatedly emphasize that "what is essential is 'the preservation of the integrity and the evidentiary value of the seized items, as the same would be utilized in the determination of the guilt or innocence of the accused.'"[23]
	GR No. 203433 2013-11-27	PEOPLE v. FAISAL LOKS Y PELONYO REYES, J.
The drug seized during the buy-bust operation, which is considered the crime's corpus delicti, was sufficiently established as containing shabu, a dangerous drug. SPO1 Velasco's marking of the seized drug immediately upon his arrival at the police station qualified as a compliance with the marking requirement. Contrary to the argument of the defense, even the buy-bust team's failure to make an inventory and to take photographs of the subject drug did not adversely affect the prosecution's case. Time and again, the Court has recognized that non-compliance with Section 21[26] of R.A. No. 9165 which identifies the said requirements does not necessarily render the arrest illegal or the items seized inadmissible. What is essential is that the integrity and evidentiary value of the seized items which would be utilized in the determination of the guilt or innocence of the accused are preserved.[27] In this case, the defense failed to substantiate its claim that such integrity and evidentiary value of the subject drug was adversely affected by the police officers' handling thereof. As the Court explained in People v. Mendoza[28]: This Court has, in many cases, held that while the chain of custody should ideally be perfect, in reality it is not, "as it is almost always impossible to obtain an unbroken chain." The most important factor is the preservation of the integrity and the evidentiary value of the seized items as they will be used to determine the guilt or innocence of the accused. Hence, the prosecution's failure to submit in evidence the physical inventory and photograph of the seized drugs as required under Article 21 of Republic Act No. 9165, will not render [the accused]'s arrest illegal or the items seized from her inadmissible.[29] (Citations omitted)
	GR No. 198794 2013-02-06	PEOPLE v. VICTOR DE JESUS Y GARCIA LEONARDO-DE CASTRO, J.
In any case, unless De Jesus can show that there was bad faith, ill will, or tampering with the evidence, the presumption that the integrity of the evidence has been preserved, and that the police officers discharged their duties properly and with regularity, will remain.[30] It is worthy to note that the ill motive De Jesus speaks of is imputed against the informant and not the police officers. This Court agrees with the Court of Appeals when it said that it is highly incredible that the arresting officers would waste their time and effort,[31] and even run the risk of losing their jobs and tainting their reputations just so they could accommodate an informant with a grudge against De Jesus.
	GR No. 187496 2013-02-06	PEOPLE v. MALIK MANALAO Y ALAUYA LEONARDO-DE CASTRO, J.
We have time and again looked upon the defense of denial with disfavor for being easily fabricated. Since Manalao failed to give this Court anything more than his bare assertions, his defense of denial must necessarily be rejected.[35]
	GR No. 188107 2012-12-05	PEOPLE v. RONALD M. DEL ROSARIO LEONARDO-DE CASTRO, J.
While it is true that in many cases[31] this Court has overlooked the non-compliance with the requirements under the foregoing provisions, it did so only when the integrity and the evidentiary value of the seized items had been preserved.
	GR No. 191532 2012-08-15	MARGARITA AMBRE Y CAYUNI v. PEOPLE MENDOZA, J.
While ideally the procedure on the chain of custody should be perfect and unbroken, in reality, it is not as it is almost always impossible to obtain an unbroken chain.[20] This Court, however, has consistently held that the most important factor is the preservation of the integrity and evidentiary value of the seized items.[21] In this case, the prosecution was able to demonstrate that the integrity and evidentiary value of the confiscated drug paraphernalia had not been compromised. Hence, even though the prosecution failed to submit in evidence the physical inventory and photograph of the drug paraphernalia with traces of shabu, this will not render Ambre's arrest illegal or the items seized from her inadmissible.