327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Is the acquittal of an accused in a drug case inevitable
when procedural lapses in the chain of custody are repeatedly committed by law
enforcement?
People of the Philippines v. Rosendo Leaño y Leaño
G.R. No. 246461 | July 28, 2020
Facts of the Case:
Rosendo Leaño y Leaño, also known as "Totong," was
charged with violations of Sections 5 (illegal sale of dangerous drugs) and 11
(illegal possession of dangerous drugs) under Article II of Republic Act No.
9165, also known as the Comprehensive Dangerous Drugs Act of 2002. The
accusations stemmed from a buy-bust operation conducted by the Balanga City
Police on July 1, 2016, where Leaño allegedly sold and possessed sachets of
methamphetamine hydrochloride (shabu). The Regional Trial Court convicted
Leaño, sentencing him to life imprisonment for the illegal sale and a maximum
of 20 years for possession. The Court of Appeals affirmed the conviction.
During the trial, the prosecution presented testimonies from
police officers who executed the buy-bust operation and forensic evidence
confirming the presence of shabu. The defense, however, claimed that the drugs
were planted by the police and that Leaño was framed. The defense also raised
several procedural issues, including breaches in the chain of custody of the
evidence.
Leaño appealed his conviction, arguing that the police
failed to follow the required procedures under Section 21 of R.A. 9165, which
is crucial in preserving the integrity of the seized drugs.
Primary Legal Issue:
Did the repeated procedural lapses committed by the police
in maintaining the chain of custody of the seized drugs render the conviction
of the accused invalid?
Ruling of the Supreme Court:
The Supreme Court ruled in favor of the appellant, Rosendo
Leaño y Leaño, and reversed the decisions of the lower courts. The Court noted
several procedural lapses in the chain of custody that significantly affected
the integrity of the evidence, including:
- The
failure to immediately mark, inventory, and photograph the seized drugs at
the place of arrest.
- The
absence of mandatory third-party witnesses (a media representative and an
elected public official) during the seizure, marking, and inventory of the
drugs, as required by law.
- The
mishandling of evidence by one of the arresting officers, who placed the
sachets of shabu in his pocket without using a proper evidence bag.
The Court stressed the importance of adhering to the chain
of custody rule in drug cases, as the illegal substance itself constitutes the
corpus delicti. The lapses in this case created reasonable doubt regarding the
integrity and identity of the drugs presented as evidence.
The Supreme Court acquitted Rosendo Leaño y Leaño due to
these serious breaches in the chain of custody.
Dispositive Portion:
"ACCORDINGLY, the appeal is GRANTED. The Decision dated
September 14, 2018 of the Court of Appeals in CA-G.R. CR-HC No. 09528 is SET
ASIDE. Appellant Rosendo Leaño y Leaño is ACQUITTED. The Director of the Bureau
of Corrections, Muntinlupa City, is ordered to a) immediately release appellant
from custody unless he is being held for some other lawful cause; and b) submit
his report on the action taken within five (5) days from notice.
Let an entry of judgment immediately issue.
SO ORDERED."
How can law enforcement improve compliance with the
chain of custody requirements to avoid jeopardizing drug convictions in the
future?
Important Doctrines:
- Chain
of Custody Rule:
- "In
drug-related cases, the chain of custody of the seized evidence must be
established with unwavering exactitude."
- Any
failure to account for each link in the chain from seizure to court
presentation may cast doubt on the integrity of the evidence.
- Insulating
Witnesses Requirement:
- Section
21 of R.A. 9165 mandates that the inventory and photographing of the
seized drugs be done in the presence of the accused and witnesses
(elected public official and media representative). Failure to secure
their presence may lead to the exclusion of evidence unless properly
justified.
- Immediate
Marking Requirement:
- The
marking of seized drugs must be done immediately upon confiscation.
Delayed marking raises the risk of tampering and substitution, which can
undermine the prosecution's case.
- Justifiable
Grounds for Noncompliance:
- Deviations
from the prescribed procedures must be justified by valid reasons, such
as threats to the safety of officers or witnesses. In the absence of such
justifications, noncompliance will invalidate the seizure and custody of
the items.
Classification of the Case: Criminal Law
From <https://chatgpt.com/c/66eeba7b-3564-800a-af55-3b17cce92108>
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🎓 INTRODUCTION TO
SUPREME COURT JURISPRUDENCE
In this legal educational content, we will explore the
landmark case of People of the Philippines v. Rosendo Leaño y Leaño, G.R.
No. 246461, promulgated on July 28, 2020, by the First Division
of the Supreme Court. This criminal case involves charges of violation
of Sections 5 and 11, Article II of Republic Act No. 9165, or the Comprehensive
Dangerous Drugs Act of 2002, as amended by RA 10640.
This video aims to guide law students and bar examinees
(baristas) in recalling and understanding the doctrinal pronouncements
of the Supreme Court, particularly involving the chain of custody rule,
the requirements under Section 21, and the standard of proof required
in dangerous drug prosecutions.
🧑⚖️ Nature of the Case:
Criminal Law
Case Title: People of the Philippines v. Rosendo
Leaño y Leaño
Date Promulgated: July 28, 2020
Parties: The People of the Philippines
(Plaintiff-Appellee) vs. Rosendo Leaño y Leaño (Accused-Appellant)
⚖️ Brief Case Summary:
Rosendo Leaño was convicted by the trial court for selling
and possessing methamphetamine hydrochloride (shabu) during a buy-bust
operation in Balanga City, Bataan. The Court of Appeals affirmed. However, the
Supreme Court acquitted him due to multiple violations of the chain
of custody rule, including failure to justify the absence of required
witnesses and unsafe handling of the drug evidence.
👉 Key Issue: Should
an accused be acquitted if the chain of custody rule under Section 21 of RA
9165 is violated without justification?
👉 Ruling: YES. The
Supreme Court emphasized that unjustified lapses in the chain of custody
create reasonable doubt, entitling the accused to an acquittal.
💡 If strict
compliance with the chain of custody rule is not followed, can our courts ever
convict anyone in drug cases without compromising justice?
📜 10 FACTUAL DOCTRINES
FROM THE CASE (G.R. No. 246461, July 28, 2020)
- Strict
Chain of Custody Is Mandatory
Failure to strictly follow Section 21 may lead to the exclusion of evidence if the identity of the drug is questionable. (Source: Supreme Court Decision) - Marking
Must Be Immediate and in the Presence of the Accused
The first link in the chain begins with proper marking at the site of arrest, witnessed by required individuals. (p. 28) - Presence
of Insulating Witnesses Is Crucial
Inventory and photographing must be witnessed by a DOJ rep, elected official, and media, unless justifiably absent. (p. 27) - Noncompliance
Requires Justification
Mere procedural lapses aren’t fatal if the police can prove valid reasons. But silence or lack of explanation is fatal. (p. 31) - Evidence
in Officer’s Pocket Is Suspicious
Keeping seized items in the arresting officer’s pocket, without proper evidence handling, undermines credibility. (p. 33) - Inventory
Must Be at the Scene, Station, or Nearest Office
Doing it elsewhere without explanation violates the law. (p. 27) - No
Link Between Arresting and Investigating Officer
A missing second link—no testimony of handover—breaks the chain of custody. (p. 35) - No
Proof of Chemist's Custody Measures
Without testimony or stipulation on how the chemist handled and secured the items, integrity is questionable. (p. 37) - Acquittal
Is Warranted When Corpus Delicti Is Compromised
Even positive drug test results can't save the case if the seized item’s identity is not proven. (p. 38) - Subsequent
Inventory Does Not Cure Initial Flaws
Late compliance with inventory and photographing cannot rectify earlier procedural breaches. (p. 32)
📢 DISCLAIMER:
This video is made for educational purposes only. It
does not guarantee the legal accuracy or completeness of any cited rulings. The
content is not legal advice. Made using premium AI to assist bar review
and jurisprudence recall.
❓Frequently Asked Questions
(FAQs)
1. What is the chain of custody rule?
It refers to the documented and unbroken transfer of
evidence from seizure to presentation in court, ensuring its integrity.
2. Why is Section 21 important in drug cases?
Because the drug is the corpus delicti (body of the
crime), and its identity must be preserved to convict.
3. Can the accused be acquitted just because the
inventory wasn’t at the crime scene?
Yes, if there's no justifiable reason for deviating from the
law’s clear procedure.
4. Can one officer handle the seized drugs alone?
It is highly discouraged. Doing so invites doubts and
potential tampering, as ruled in this case.
5. Does a positive drug test prove possession or sale?
No. It may support suspicion, but the chain of custody and
integrity of the seized items must still be proven.
Want us to cover another jurisprudence next? Comment below
with your case suggestions! 👇
#PhilippineLaw #ChainOfCustody #CriminalLaw #BarReviewPH
#RA9165 #JurisprudenceDigest #SCDecisions #EducationalVideo
From <https://chatgpt.com/g/g-ipZC0xKZ1-case-digest/c/66eeba7b-3564-800a-af55-3b17cce92108>
🎓 INTRODUCTION TO THE
CRIMINAL LAW QUIZZER
(For Law Students, Bar Reviewees, and Legal Educators)
Welcome, future lawyers! In this short but focused quizzer,
we will test your understanding of a vital Supreme Court jurisprudence in Criminal
Law, specifically under dangerous drugs law and the chain of custody
doctrine.
This quizzer is based on the case of People of the
Philippines v. Rosendo Leaño y Leaño, G.R. No. 246461, promulgated
on July 28, 2020, by the First Division of the Supreme Court.
⚖️ Nature of the Case:
Criminal Law – Violation of the Dangerous Drugs Act (Sale
and Possession of Illegal Drugs)
📌 Case Summary (Brief):
Rosendo Leaño was convicted of selling and possessing
methamphetamine hydrochloride (shabu) following a police buy-bust operation.
The lower courts found him guilty. However, the Supreme Court reversed the
decision and acquitted him due to multiple procedural lapses in the chain
of custody of the seized evidence. The Court emphasized that unjustified
noncompliance with procedural safeguards creates reasonable doubt and renders
the evidence inadmissible.
📘 REMINDER:
Answer key will be provided at the end of the video,
so try your best before checking your score.
✅ QUIZZER: HOTS (Higher Order
Thinking Skills)
Easy Difficulty – Multiple Choice Questions
1. What was the primary reason the Supreme Court
acquitted the accused in this case?
A. The accused admitted guilt during cross-examination
B. The accused proved he was not at the crime scene
C. The chain of custody rule was violated
D. The laboratory results were invalid
2. In the decision, how did the police officer store
the seized sachets after the arrest?
A. He placed them in an evidence bag immediately
B. He turned them over directly to the chemist
C. He kept them in his left and right pockets
D. He handed them to the DOJ representative
3. Why was the presence of specific witnesses during
seizure and inventory deemed critical?
A. To serve as backup in case of violent resistance
B. To provide moral support to the police
C. To prevent allegations of evidence planting
D. To help in searching the suspect
4. What did the Court say about conducting the
inventory and photographing at the police station instead of the arrest site?
A. It is acceptable without condition
B. It is always better to do it at the police station
C. It requires justification if not done at the site
D. It has no bearing on the case
5. What was missing in the second link of the chain
of custody?
A. Laboratory results
B. Identification of the sachets
C. Testimony on the handover to investigating officer
D. Presence of barangay officials
6. What procedural act did the forensic chemist fail
to establish due to insufficient stipulations?
A. Conducting the buy-bust operation
B. Marking the scene with chalk
C. Taking steps to preserve integrity of evidence
D. Taking photographs of the crime
7. Why did the Court view the handling of evidence by
the arresting officer as suspicious?
A. Because he was alone in the operation
B. Because he laughed during cross-examination
C. Because the items were kept in his own pockets
D. Because he left the scene early
8. According to the Court, what is the effect of
unjustified failure to comply with procedures in illegal drug cases?
A. The accused is only fined
B. It does not matter if the drug is real
C. It may lead to acquittal due to reasonable doubt
D. The officer is suspended
9. What kind of seizure did the Court categorize the
operation as?
A. Seizure under warrant
B. In flagrante delicto or warrantless seizure
C. Citizen’s arrest
D. Judicial enforcement seizure
10. Which of the following was one of the Court's key
recommendations to avoid future lapses?
A. Conduct operations in remote locations
B. Always invite the media as witnesses
C. Comply strictly with custody procedures and document all
links
D. Focus only on the testimony of the poseur-buyer
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