327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Did the police officers' failure to secure the presence of a
media and Department of Justice (DOJ) representative during a buy-bust
operation fatally compromise the chain of custody, leading to the acquittal of
an accused charged with illegal drug sale?
People of the Philippines vs. Joey Nabua y Campos
G.R. No. 235785, August 14, 2019
FACTS OF THE CASE:
Joey Nabua y Campos was charged with violating Section 5,
Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002)
after a buy-bust operation conducted by the Rosario Police in La Union. He was
accused of selling a sachet of methamphetamine hydrochloride
("shabu") to a police officer who acted as a poseur-buyer. The
operation, coordinated by a confidential informant, resulted in Nabua's arrest
and the confiscation of two plastic sachets of shabu.
The buy-bust team testified that the operation followed a
pre-arranged signal, after which they arrested Nabua and marked the confiscated
items. However, it was revealed during the trial that the marking, inventory,
and photography of the seized drugs were conducted in the presence of barangay
officials but without the required representatives from the media and DOJ.
Despite these omissions, the trial court convicted Nabua, sentencing him to
life imprisonment and a fine of PHP 500,000.
On appeal, Nabua argued that the omissions in the chain of
custody rendered the evidence inadmissible, as the absence of media and DOJ
representatives opened the process to possible tampering. The Court of Appeals
affirmed the trial court’s decision, maintaining that the prosecution had
substantially complied with the chain of custody rule.
PRIMARY ISSUE:
Did the Court of Appeals err in affirming the conviction
despite significant lapses in the chain of custody of the seized drugs,
particularly the absence of media and DOJ witnesses during the inventory?
RULING OF THE SUPREME COURT:
The Supreme Court reversed the decision of the Court of
Appeals and acquitted Nabua. It held that the lapses in the chain of custody
were serious enough to cast doubt on the integrity and evidentiary value of the
seized drugs. The Court emphasized that the presence of witnesses such as a
media representative and a DOJ representative is required under Section 21 of
R.A. 9165 to ensure the integrity of the process. The police officers failed to
justify their non-compliance with this rule, and there was no valid explanation
provided for the absence of these witnesses.
The Supreme Court reiterated that strict adherence to the
chain of custody rule is necessary to prevent tampering, substitution, or
contamination of the evidence. In the absence of a valid explanation for
non-compliance, the integrity of the corpus delicti was compromised,
necessitating Nabua’s acquittal.
DISPOSITIVE PORTION:
The Supreme Court granted the appeal, reversed the decision
of the Court of Appeals, and acquitted Joey Nabua y Campos. The Court ordered
his immediate release from custody unless he was being held for another lawful
cause.
THOUGHT-PROVOKING QUESTION:
Should procedural lapses in the handling of evidence, even
without proof of actual tampering, always result in an acquittal to uphold
constitutional rights?
IMPORTANT DOCTRINES DISCUSSED:
- Chain
of Custody Rule (R.A. 9165, Section 21):
To ensure the integrity of seized drugs, the law requires the presence of specific witnesses, including representatives from the DOJ, the media, and elected public officials. Failure to secure these witnesses without justifiable grounds may compromise the admissibility of evidence. - Presumption
of Regularity vs. Strict Compliance:
The presumption of regularity in the performance of official duties cannot be invoked when procedural safeguards, especially those designed to protect the accused's rights, are violated. Non-compliance with the chain of custody rule can override the presumption of regularity in police operations. - Saving
Clause in Section 21 (R.A. 9165):
The law allows leniency in the strict application of the chain of custody rule, provided that justifiable reasons are offered and the integrity of the seized drugs is preserved. However, the prosecution bears the burden of proving these justifications, failing which, the evidence may be deemed inadmissible.
This case falls under Criminal Law, specifically
focusing on the application and interpretation of procedural rules in
drug-related offenses.
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🎓 INTRODUCTION FROM A
PHILIPPINE LAW PROFESSOR:
Welcome, future lawyers and baristas! In this brief
jurisprudential digest, we explore a landmark Supreme Court decision that
reaffirms the sanctity of procedural safeguards in drug-related prosecutions.
This content will help you recall key doctrines, particularly regarding
the chain of custody rule under R.A. 9165, essential for bar review and
classroom study.
📚 CASE NATURE:
Criminal Law – Illegal Sale of Dangerous Drugs
CASE TITLE: People of the Philippines vs. Joey
Nabua y Campos
PARTIES: The People of the Philippines
(Plaintiff-Appellee) vs. Joey Nabua y Campos (Accused-Appellant)
G.R. No.: 235785
DATE OF PROMULGATION: August 14, 2019
📝 BRIEF CASE SUMMARY
& ISSUE:
Joey Nabua was convicted of selling P500 worth of shabu in a
buy-bust operation. However, the arresting officers failed to secure the
presence of media and DOJ representatives during the inventory of the
seized items. The Supreme Court reversed his conviction, emphasizing the
importance of the chain of custody rule and the mandatory presence of
witnesses.
Should a drug suspect walk free just because the arresting
officers failed to comply with technical rules—even if drugs were allegedly
found?
💬 Comment below and share
your take.
📌 10 IMPORTANT DOCTRINES
FROM THE CASE (FOR YOUTUBE AND SOCIAL MEDIA POSTS):
- Chain
of Custody Rule (Sec. 21, R.A. 9165)
Failure to strictly observe the mandatory presence of witnesses during inventory breaks the evidentiary chain. (See full case text, Supreme Court ruling) - Four
Links in Chain of Custody Must Be Proven
Seizure → Turnover to Investigator → Transfer to Forensic Chemist → Presentation in Court. Missing any link compromises the integrity of the evidence. (People v. Nabua, G.R. No. 235785) - Presumption
of Regularity Cannot Override Violations
The presumption in favor of police duties cannot cure clear procedural lapses. (Citing Supreme Court decision, Nabua case) - Presence
of Media, DOJ, and Elected Official is Mandatory
Sec. 21 requires their presence unless a justifiable ground is explained. Here, no effort to contact them was shown. (TSN, August 5, 2014; February 24, 2015) - Failure
to Preserve Evidence Integrity Is Fatal
The prosecution must prove how seized drugs were preserved, especially when in forensic custody. (Citing People v. Hementiza) - Saving
Clause Not Automatically Applicable
Non-compliance can only be excused with justifiable reasons and proof that integrity was preserved. (Sec. 21(a), IRR of R.A. 9165) - Chain
of Custody Must Be Documented
Every transfer and handling of evidence must be supported by records and witness testimony. (People v. Dahil, 750 Phil. 212) - Burden
on the Prosecution to Justify Lapses
Failure to present reasons for non-compliance nullifies the presumption of regularity. (People v. Crispo, G.R. No. 230065) - Forensic
Chemist's Custody Must Be Proven
The chemist must detail handling, storage, and presentation in court—not just test results. (People v. Nabua case, citing PSI Manuel’s limited testimony) - Acquittal
Required When Evidence is Tainted
Conviction requires proof beyond reasonable doubt. Here, procedural gaps made this standard unmet. (Final Supreme Court ruling in Nabua case)
⚖️ LEGAL CLASSIFICATION:
Criminal Law – Focus on drug-related prosecution and
evidentiary chain of custody.
❓ FREQUENTLY ASKED QUESTIONS:
Q1: What is the chain of custody?
It refers to the process that ensures seized drugs remain
untampered from seizure to court presentation.
Q2: What if DOJ and media witnesses are absent?
The arresting team must provide a justifiable reason.
Without one, the evidence becomes questionable.
Q3: Why was Nabua acquitted?
Due to serious lapses in the chain of custody and the
absence of required witnesses during the inventory.
Q4: Can procedural lapses really lead to acquittal?
Yes. Compliance with procedure is as important as the
substance of the offense.
Q5: Is this ruling final?
Yes, it was promulgated by the Supreme Court and serves as
binding precedent.
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