327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Is the absence of critical witnesses during a buy-bust
operation enough to overturn a conviction for illegal drug sale, despite the
presumption of regularity in police operations?
People of the Philippines vs. Shager Lacdan y Parto
G.R. No. 232161, August 14, 2019
Facts of the Case:
Shager Lacdan y Parto was charged with violating Section
5, Article II of Republic Act 9165 (Comprehensive Dangerous Drugs Act of 2002).
The charge stemmed from a buy-bust operation conducted by the police on March
3, 2013, in San Pedro, Laguna. During the operation, Lacdan allegedly sold
0.04 grams of methamphetamine hydrochloride (shabu) to PO2 Alexander Gallega,
who was acting as a poseur-buyer. Upon his arrest, Lacdan was also found in
possession of marked buy-bust money. A plastic sachet containing the illegal
substance was submitted for forensic examination, which confirmed that it was
methamphetamine hydrochloride. Lacdan denied the charges, claiming he was
wrongly accused and arrested while seated outside his house.
The Regional Trial Court (RTC) convicted Lacdan of
the offense, sentencing him to life imprisonment and imposing a fine of P500,000.
On appeal, the Court of Appeals (CA) affirmed the conviction, giving
weight to the presumption of regularity in the performance of the duties of the
police officers involved in the operation.
Primary Legal Issue Raised to the Supreme Court:
Was the chain of custody rule complied with, and was the
integrity of the corpus delicti (the seized drugs) preserved in accordance with
Section 21 of RA 9165?
Decision of the Supreme Court:
The Supreme Court reversed the conviction and acquitted
Shager Lacdan on the grounds of multiple breaches in the chain of
custody rule, which cast doubt on the integrity of the drugs presented as
evidence. Specifically, the prosecution failed to ensure the presence of the
required witnesses, such as a representative from the Department of Justice
(DOJ) and an elected public official, during the physical inventory and
photographing of the seized drugs at the scene of the arrest. The absence of
these crucial witnesses, as required by Section 21 of RA 9165, was not
explained by the arresting officers. Furthermore, gaps in the chain of custody
were noted, such as the failure to identify who handled the drugs at different
points in the process, leaving room for potential tampering.
The Court reiterated that strict compliance with the
chain of custody rule is vital to ensure the integrity of the seized evidence,
and any unexplained breach in the rule raises doubts about the guilt of the
accused.
Dispositive Portion of the Decision:
The Supreme Court ruled as follows:
"The appeal is GRANTED. The Decision dated September
15, 2016 of the Court of Appeals in CA-G.R. CR-HC No. 07794 is REVERSED AND SET
ASIDE. Appellant Shager Lacdan y Parto is ACQUITTED of violation of Section 5,
Article II of Republic Act 9165.
The Court further DIRECTS the Director of the Bureau of
Corrections, Muntinlupa City: (a) to cause the immediate release of Shager
Lacdan y Parto from custody unless he is being held for some other lawful
cause; and (b) to inform the Court of the action taken within five (5) days
from notice.
Let entry of judgment immediately issue."
If non-compliance with the chain of custody rule leads to
acquittal, does this signal a potential loophole in drug enforcement operations
that may allow actual offenders to escape liability?
Important Doctrines Discussed:
- Chain
of Custody Rule
The chain of custody is the process of safeguarding the seized drugs from the time of confiscation to the presentation in court to prevent tampering, substitution, or alteration. Any break in the chain, unless justifiable, renders the evidence inadmissible and leads to acquittal. - Section
21 of RA 9165
Requires that seized drugs be inventoried and photographed in the presence of the accused, a representative from the media, a representative from the Department of Justice (DOJ), and an elected public official. The absence of any of these witnesses, without justifiable reason, raises doubts about the integrity of the evidence. - Presumption
of Regularity vs. Strict Adherence to Procedure
The presumption of regularity in police operations cannot prevail over constitutional and statutory rights of the accused, especially when there are significant procedural lapses.
Classification: Criminal Law / Remedial Law (due to
procedural focus on the chain of custody rule).
From <https://chatgpt.com/c/66eeba25-7758-800a-a7a5-6e1b4aad3884>
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🎓 INTRODUCTION TO A
LANDMARK CASE IN PHILIPPINE CRIMINAL LAW
In this educational content, we explore a pivotal Supreme
Court decision that dissects the "chain of custody" rule in illegal
drug prosecutions — a cornerstone principle in criminal law practice. This
discussion is designed especially for law students and bar examinees (baristas)
who aim to master legal doctrines crucial for both academic and professional
success.
We will analyze the legal issues and doctrines laid down in:
🔹 Title: People of the
Philippines vs. Shager Lacdan y Parto
🔹 G.R. No.: 232161
🔹 Date of Promulgation:
August 14, 2019
🔹 Nature of the Case:
Criminal Law – Violation of Section 5, Article II of RA 9165 (Illegal Sale of
Dangerous Drugs)
🔍 Brief Summary of the
Case:
Accused Shager Lacdan was charged with selling shabu in a
buy-bust operation. He was convicted by the RTC and the Court of Appeals, but
on appeal, the Supreme Court acquitted him due to multiple, unjustified
violations of the chain of custody rule under RA 9165. The Court emphasized
that failure to follow mandatory procedures on the seizure, inventory, and
handling of evidence seriously compromised the integrity of the corpus delicti
(the drug itself).
✅ The main issue: Was the chain
of custody rule complied with?
❌ The SC said No. Hence, the conviction
was reversed and Lacdan was acquitted.
🧠 “Should poor police
compliance with procedural safeguards automatically result in acquittal, even
if drug trafficking is a serious crime?”
👉 Comment your thoughts
below!
📘 Top 10 Doctrines from
the Case (Factual Summary):
- Chain
of Custody is Mandatory.
The chain of custody rule must be strictly followed to establish the integrity and identity of the seized drugs.
📖 [See: Decision, pp. 8–10] - Three-Witness
Rule in Inventory.
The inventory must be witnessed by the accused, a DOJ representative, a media rep, and an elected official.
📖 [See: Section 21, RA 9165 and IRR] - Non-compliance
Must Be Justified.
If the three-witness rule is not followed, authorities must give valid justification.
📖 [See: Decision, p. 12] - Unjustified
Lapses = Acquittal.
Absence of key witnesses without explanation seriously impairs the prosecution’s case.
📖 [See: People v. Seguiente, cited in Decision, p. 13] - Corpus
Delicti = The Drug Itself.
The drug is the very subject of the crime; its identity must be proven unbroken.
📖 [See: Decision, p. 10] - No
Turnover to Investigating Officer.
Failure to show who handled the drug after seizure breaks the chain.
📖 [See: Decision, p. 14] - Unidentified
Crime Lab Clerk = Gap.
The prosecution did not name or present the crime lab receiving clerk.
📖 [See: Decision, p. 15] - Evidence
Custodian Procedures Matter.
The forensic chemist’s hand-off to the custodian must be accounted for.
📖 [See: Decision, p. 16] - Presumption
of Regularity Not Absolute.
It cannot prevail over clear procedural lapses in handling drug evidence.
📖 [See: Decision, p. 12] - Mallillin
Doctrine on Evidence Authentication.
All handlers of evidence must be identified and account for the item’s condition.
📖 [See: Mallillin v. People, cited in Decision, p. 16]
⚖️ DISCLAIMER:
This video is for educational purposes only and does not
claim to be legally infallible. Always refer to the official Supreme Court
decision and your academic materials. This content was made using premium AI
tools to support legal learning and review.
❓ Frequently Asked Questions
(FAQs):
Q1: What is the Chain of Custody Rule?
A1: It's a legal requirement that tracks every link in the
handling of seized illegal drugs to ensure evidence integrity from seizure to
court presentation.
Q2: What happens if the chain of custody is broken?
A2: The accused may be acquitted, as the integrity of the
drug evidence becomes doubtful.
Q3: Is the presence of a DOJ representative mandatory during
inventory?
A3: Yes. Their absence, unless justified, invalidates the
procedure.
Q4: Can the police's presumption of regularity save the
case?
A4: Not if clear procedural violations are proven.
Q5: Is this doctrine still applicable under the amended RA
9165?
A5: Yes. The principles apply unless specifically modified
by law or jurisprudence.
🎓 INTRODUCTION TO THE
QUIZZER: SUPREME COURT JURISPRUDENCE ON DRUG CASES
Welcome to this legal quizzer designed for law students
and bar reviewees!
This quizzer is based on the landmark Supreme Court ruling
in the case of:
🔹 Title: People
of the Philippines vs. Shager Lacdan y Parto
🔹 Date of
Promulgation: August 14, 2019
🔹 Nature of the Case:
Criminal Law – Violation of laws prohibiting the sale of illegal drugs
This case centers on the alleged illegal sale of a dangerous
drug (shabu) during a police buy-bust operation. The accused, Shager Lacdan,
was initially convicted by the trial court and the Court of Appeals. However,
on final appeal, the Supreme Court reversed the conviction and acquitted the
accused due to serious lapses in the observance of the chain of custody
rule—a critical safeguard in drug-related prosecutions.
The Court emphasized the non-compliance with mandatory
procedures, such as the absence of required witnesses during the physical
inventory of seized items and the unexplained gaps in the handling of evidence.
These failures led the Court to conclude that the integrity of the drug
evidence had been compromised.
📌 The central issue: Was
the chain of custody rule strictly followed by law enforcement?
✅ Ruling: No. Hence, the
Supreme Court acquitted the accused.
Stay tuned until the end of the quiz video for the answer
key to help you assess your understanding and reinforce learning!
🔍 HOTS MULTIPLE CHOICE
QUESTIONS (Easy Difficulty)
1. What was the ultimate reason why the Supreme Court
acquitted the accused in the case?
A. Lack of jurisdiction
B. Mistaken identity
C. Breach in the handling of drug evidence
D. Lack of probable cause
2. Which of the following was absent during the
physical inventory that contributed to the accused’s acquittal?
A. The poseur-buyer
B. A barangay tanod
C. A DOJ representative and an elected official
D. The accused's lawyer
3. What is the significance of the chain of custody
rule in illegal drug prosecutions?
A. It prevents unlawful search and seizure
B. It ensures proper sentencing
C. It validates the arrest procedure
D. It preserves the identity and integrity of the evidence
4. Which procedural lapse did the arresting officers
fail to justify in the case?
A. The lack of search warrant
B. The presence of only one witness during inventory
C. The absence of a Miranda warning
D. The failure to detain the accused
5. What does the Supreme Court emphasize about
non-compliance with evidence-handling rules?
A. It can be overlooked if there is strong circumstantial
evidence
B. It always leads to conviction
C. It must be justified, or it may lead to acquittal
D. It is irrelevant in drug cases
6. Why did the Court find the chain of custody to be
broken in this case?
A. The police failed to arrest the accused properly
B. The name of the receiving clerk at the crime lab was not
disclosed
C. The drugs were destroyed before trial
D. The accused denied the charges
7. What was the consequence of failing to present the
receiving clerk from the crime laboratory?
A. It proved conspiracy
B. It rendered the evidence inadmissible
C. It had no legal effect
D. It delayed the trial
8. In the decision, what did the Supreme Court say
about the presumption of regularity?
A. It outweighs all procedural lapses
B. It is irrelevant in criminal trials
C. It cannot override clear violations of required
procedures
D. It only applies in civil cases
9. What is the legal consequence when the integrity
of the seized drugs is cast in doubt?
A. The court may impose a lesser penalty
B. The prosecution may restart its case
C. The accused must be acquitted
D. The evidence can still be admitted if the chemist
testifies
10. What critical legal standard must be established
for a valid conviction in drug sale cases?
A. The quantity of the drugs
B. The exact time of arrest
C. The unbroken chain of custody
D. The confession of the accused
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