Scribd
Upload
739 views1 page

People v. Dahil - Case Digest

The accused, Dahil and Castro, were charged with illegal sale and possession of marijuana following a buy-bust operation. They claimed frame-up and irregularities in preserving the seized items. The court found no substantial compliance with chain of custody requirements, as the inventory was only done at the police station without proper equipment, markings were also done there, the person who prepared the inventory was unclear, and it was unclear who received the drugs at the crime lab. Due to these lapses, the items were found inadmissible and the accused were acquitted. However, the court also held that substantial compliance is sufficient for admissibility, and non-compliance affects evidentiary weight, not admissibility.

Uploaded by

shezeharadeyahoocom
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
739 views1 page

People v. Dahil - Case Digest

The accused, Dahil and Castro, were charged with illegal sale and possession of marijuana following a buy-bust operation. They claimed frame-up and irregularities in preserving the seized items. The court found no substantial compliance with chain of custody requirements, as the inventory was only done at the police station without proper equipment, markings were also done there, the person who prepared the inventory was unclear, and it was unclear who received the drugs at the crime lab. Due to these lapses, the items were found inadmissible and the accused were acquitted. However, the court also held that substantial compliance is sufficient for admissibility, and non-compliance affects evidentiary weight, not admissibility.

Uploaded by

shezeharadeyahoocom
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 1

14. G.R. No.

212196               January 12, 2015


PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RAMIL DORIA DAHIL
and ROMMEL CASTRO y CARLOS, Accused-Appellants.
As a result of a buy-bust operation conducted by PDEA, Dahil and Castro were
charged with illegal sale and possession of marijuana. The accused interposed
the defense of frame-up and the irregularities in the preservation of the
integrity and evidentiary value of the seized items.
As for the chain of custody, the following events were noted:
1. the inventory of the seized items was conducted only at the police station
because the officers did not bring with them the material or equipment
for the preparation of the documents;
2. The markings were also placed at the police station
3. there is doubt as to the identity of the person who prepared the Inventory
of Property Seized;
4. there were conflicting claims on whether the seized items were
photographed in accordance with the law
5. There was lack of information as to who received the subject drugs in the
crime laboratory
Issues:
1. WON there was substantial compliance with the chain of custody.
2. WON the seized items are admissible in evidence.
Held:
1. No, there was no substantial compliance with the chain of custody.
In view of above stated serious lapses, it can be concluded that there was
no compliance with the procedural requirements of Section 21 of R.A. No.
9165 because of the inadequate physical inventory and the lack of
photography of the marijuana. No explanation was offered for the non-
observance of the rule. The prosecution miserably failed to prove that the
integrity and the evidentiary value of the seized items were preserved.
The four links required to establish the proper chain of custody were
breached with irregularity and lapses. Hence, the accused were
acquitted.

2. Yes, the seized items are admissible. Notwithstanding the failure of the
prosecution to establish the rigorous requirements of Section 21 of R.A.
No. 9165, jurisprudence dictates that substantial compliance is
sufficient. Failure to strictly comply with the law does not necessarily
render the arrest of the accused illegal or the items seized or confiscated
from him inadmissible. The issue of non-compliance with the said
section is not of admissibility, but of weight to be given on the evidence.

You might also like

pFad - Phonifier reborn

Pfad - The Proxy pFad of © 2024 Garber Painting. All rights reserved.

Note: This service is not intended for secure transactions such as banking, social media, email, or purchasing. Use at your own risk. We assume no liability whatsoever for broken pages.


Alternative Proxies:

Alternative Proxy

pFad Proxy

pFad v3 Proxy

pFad v4 Proxy