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SC Ruling - G.R. No. 224581, October 09, 2024

Author: 79467545 67 views • 2025-02-01 17:55:05


SUPREME COURT RULING The Supreme Court reversed the conviction and acquitted the accused, holding that the prosecution failed to establish the identity and integrity of the corpus delicti due to significant lapses in the chain of custody. The Court stressed that Section 21 of R.A. 9165 strictly requires the immediate marking and inventory of seized items in the presence of insulating witnesses (media, DOJ, and barangay officials). Here, these witnesses were absent at the time of apprehension and only arrived 30 minutes later, after the evidence had already been marked and handled by police officers. This delay created an opportunity for tampering and contamination of evidence, thereby breaking the chain of custody. The Court emphasized that the presence of insulating witnesses is not a mere procedural formality but a crucial safeguard against evidence planting. The prosecution’s failure to justify this non-compliance rendered the seized evidence unreliable. Furthermore, citing Carpio v. Court of Appeals, the Supreme Court reiterated that unexplained lapses in the chain of custody create reasonable doubt as to whether the drugs presented in court were the same ones allegedly seized from the accused. Since the identity of the seized items was compromised, the Court ruled that the accused must be acquitted as a matter of law. 🥑, Love our content? Keep it going by clicking on the 🟧 on this page. Your support makes a difference—THANK YOU! Given these substantial procedural lapses, the Supreme Court declared that the prosecution failed to meet the required quantum of proof beyond reasonable doubt. Accordingly, Rebutazo and Rebuton were acquitted, and their immediate release was ordered. PP vs. Melendez et al. G.R. No. 224581, October 09, 2024 Author’s note The Supreme Court granted the appeal and acquitted the accused, holding that the break in the chain of custody created reasonable doubt. The prosecution’s failure to comply with Section 21 of R.A. 9165 warranted acquittal, reinforcing the principle that strict adherence to procedural safeguards is mandatory in drug-related cases. This ruling ensures that convictions in drug cases must be based on clear, unbroken evidence, and any failure to follow legal procedures may result in acquittal due to reasonable doubt. RELATED INSULATING WITNESSES Insulating witnesses are independent third-party individuals required by Section 21 of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) to be present during the inventory and documentation of seized illegal drugs in drug-related operations. Their presence is intended to prevent evidence tampering, planting, or contamination, ensuring the integrity and credibility of the seized items. Who Are the Insulating Witnesses? Under Section 21, Article II of R.A. 9165, as amended by R.A. 10640, the following three insulating witnesses must be present during the physical inventory and taking of photographs of the seized drugs at or near the place of apprehension: 1. A representative from the media 2. A representative from the Department of Justice (DOJ) 3. An elected barangay official Purpose of Insulating Witnesses • To guard against police abuse or evidence planting. • To authenticate the inventory and documentation process of the seized drugs. • To strengthen the credibility of the prosecution’s evidence by ensuring that proper procedures were followed. 🥑, Love our content? Keep it going by clicking on the 🟧 on this page. Your support makes a difference—THANK YOU! Failure to secure the presence of these witnesses without a justifiable reason creates a break in the chain of custody, which can result in the exclusion of the evidence and the acquittal of the accused, as seen in the Supreme Court ruling in People v. Rebutazo & Rebuton.

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