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People vs. Rivera y Suarez 1 Case Digest XXX

The Supreme Court acquitted the accused-appellants of illegal drug charges, finding that the prosecution failed to establish an unbroken chain of custody over the seized drugs. Specifically, while the parties stipulated that the forensic chemist received and examined the seized items, they did not stipulate as to how the items were handled, stored, and preserved at the crime laboratory after examination. Establishing each link in the chain of custody is crucial to preserving the integrity of evidence, and the lack of stipulations regarding the fourth link resulted in reasonable doubt about the identity of the seized drugs. Consequently, the Court ruled that the accused-appellants' guilt was not proven beyond reasonable doubt.

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763 views2 pages

People vs. Rivera y Suarez 1 Case Digest XXX

The Supreme Court acquitted the accused-appellants of illegal drug charges, finding that the prosecution failed to establish an unbroken chain of custody over the seized drugs. Specifically, while the parties stipulated that the forensic chemist received and examined the seized items, they did not stipulate as to how the items were handled, stored, and preserved at the crime laboratory after examination. Establishing each link in the chain of custody is crucial to preserving the integrity of evidence, and the lack of stipulations regarding the fourth link resulted in reasonable doubt about the identity of the seized drugs. Consequently, the Court ruled that the accused-appellants' guilt was not proven beyond reasonable doubt.

Uploaded by

Marianne Nicer
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© © All Rights Reserved
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PEOPLE vs.

RIVERA y SUAREZ
G.R No. 252886, March 15, 2021

FACTS:
Members of the Marikina Police Station prepared to conduct a buy-bust operation against them,
with in Marikini City where PO3 Basang was the poseur-buyer. At the target area, the
Confidential Informant (CI) knocked at the door of the said house while calling "Doc Aga." After
Rivera opened the door, the CI introduced PO3 Basang as the buyer, who then informed the
former that he will buy shabu . Thereafter, Rivera shouted to Estanislao, to bring shabu to which
the latter complied. After Rivera handed a heat-sealed plastic sachet containing 0.11 gram of
white crystalline substance to PO3 Basang, the latter secretly performed the pre-arranged
signal resulting in the arrest of accused-appellants. When PO3 Basang searched accused-
appellants subsequent to their arrest, he recovered grams of shabu and Drug Paraphernalia.
Immediately thereafter, PO3 Basang conducted the marking, inventory, and photography of the
seized items at the place of arrest and in the presence of accused-appellants, Barangay
Captain, Vice Mayor, and a representative from the media. Subsequently, accused-appellants
and the seized items, which were in the custody of PO3 Basang, were brought to the police
station, where the necessary paperworks were prepared. PO3 Basang then brought accused-
appellants to the hospital for a routine examination, and the seized items to the crime
laboratory, which were received by forensic chemist. Upon qualitative examination, the seized
items tested positive for methamphetamine hydrochloride or shabu. During trial, however, the
parties opted to dispense with PCI Libres' testimony, and in lieu thereof, entered into
stipulations as to its supposed contents of the evidence received.

Rivera and Estanislao raised the defense that they were framed by the police officers and were
both threatened while peacefully being in their homes. That both were asked go to the second
floor and were asked questions and later on were threatened by said officers. After so they were
asked to go down and started taking pictures with the shabu.

RTC found the accused-apellants guilty of Illegal Possession of Drugs and Illegal Possession of
Drug Paraphernalia. Upon appeal, the CA affirmed the RTC ruling with modification acquitting
Rivera on the ground of reasonable doubt since the paraphernalia was retrieved from Estanislao
alone.

ISSUE:
WON accused-appellants are guilty beyond reasonable doubt of the crimes charged.

RULING:
No, the accused-apellants are not guilty.
It is essential that the identity of the seized drug/paraphernalia be established with moral
certainty. Thus, in order to obviate any unnecessary doubts on such identity, the prosecution
has to show an unbroken chain of custody over the same. As regards the fourth link, case law
provides that ''it is of paramount necessity that the forensic chemist testifies on the details
pertaining to the handling and analysis of the dangerous drug submitted for examination In other
words, if the forensic chemist's testimony is dispensed with, the parties must agree to stipulate
that: (a) the forensic chemist received the seized article as marked, properly sealed, and intact;
(b) he/she resealed it after examination of the contents; and (c) he/she placed his/her own
marking on the same to ensure that it could not be tampered pending trial. Absent such
stipulations, the fourth link cannot be established, thus, resulting in acquittal/s It must be
recalled that during trial, the parties opted to dispense with the testimony of PCI Libres, the
forensic chemist. From the foregoing, it would then appear that while the parties stipulated as to
the manner the seized items were received by the chemist and as to the results of the
examination thereof, there were no such
stipulations as to the manner the seized items were managed, stored, preserved or handled at
the crime laboratory after it was examined by PCI Libres and before it was delivered to the trial
court for identification. Absent these required stipulations, the fourth link of the chain of custody
could not be reasonably established. The lapses committed by the prosecution and the law
enforcers herein could not be considered minor. Indeed, establishing every link in the chain of
custody is crucial to the preservation of the integrity, identity, and evidentiary value of the seized
items

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