A man convicted of selling and possessing shabu was sentenced to life imprisonment. The police had presented photographs of the seized drugs, inventory documents, laboratory results, and records showing how the evidence was transferred.
To an ordinary observer, the prosecution's case might have appeared convincing. But when the case reached the Supreme Court, several overlooked details changed the outcome.
In People of the Philippines v. Katchan Irizumi y Borromeo, G.R. No. 270344, April 23, 2026, the Supreme Court acquitted the accused of illegal sale and illegal possession of dangerous drugs under Sections 5 and 11 of Republic Act No. 9165.
The reason was not a single technical mistake. The Court identified multiple failures in the handling and preservation of the alleged drugs, creating reasonable doubt about whether the evidence presented in court was the same evidence supposedly seized during the police operation.
The Case: A Buy-Bust Operation in Batangas City
On April 28, 2021, police officers conducted a buy-bust operation in Batangas City against Katchan Irizumi, also known as “Hapon.”
According to the police, an undercover officer purchased a sachet containing 0.22 gram of shabu from Irizumi for ₱2,000. After the transaction, officers arrested him and allegedly recovered 14 additional sachets containing a total of 56.23 grams of shabu.
The seized items were marked, photographed, inventoried, and submitted for laboratory examination. The forensic chemist confirmed that the specimens tested positive for methamphetamine hydrochloride.
The Regional Trial Court convicted Irizumi on both charges and imposed life imprisonment for each offense. The Court of Appeals affirmed.
However, the Supreme Court found serious problems in the prosecution's compliance with the chain of custody requirements under Section 21 of RA 9165.
Why Did the Supreme Court Acquit the Accused?
The Court identified five significant deficiencies that undermined the integrity of the seized drugs.
1. The Barangay Official Was Not Readily Available at the Place of Arrest
Under Section 21 of RA 9165, as amended by RA 10640, the inventory and photographing of seized dangerous drugs must be conducted in the presence of the accused or an authorized representative, an elected public official, and a representative of the National Prosecution Service or the media.
In Nisperos v. People, the Supreme Court clarified that the required witnesses must be at or near the place of apprehension, ready to witness the inventory immediately following the seizure.
In Irizumi's case, the barangay captain initially declined to accompany the police officers because she feared for her safety. Instead, she remained at the barangay hall and was instructed to wait for a telephone call if the operation succeeded.
The police called her only after Irizumi had already been arrested. Although she eventually witnessed the inventory, the Supreme Court ruled that calling an insulating witness only after the seizure did not satisfy the requirement that the witness be readily available.
The presence of a media representative during the operation did not cure the absence of the other required witness.
2. The Police Failed to Justify the Absence of the Required Witness
The police argued that they had difficulty securing witnesses because the operation occurred late at night during the COVID-19 pandemic.
The Supreme Court rejected these explanations.
The prosecution failed to identify the other potential witnesses contacted, how they were contacted, or what efforts were actually made to secure their attendance. There was also no proof that the operation was so urgent that the officers could not make additional arrangements.
The Court stressed that buy-bust operations are generally planned activities. Police officers therefore have an opportunity to arrange for the presence of mandatory witnesses. A general claim that witnesses were unavailable, or that the pandemic made compliance difficult, is not enough without specific supporting evidence.
3. The Seized Drugs Were Not Properly Marked
The Supreme Court also examined the markings placed on the confiscated sachets.
Under the 2014 Revised Philippine National Police Manual on Anti-Illegal Drugs Operations and Investigation, the seizing officer must indicate identifying information that includes the date, time, and place of seizure.
In this case, the markings contained the officer's initials, signature, and date, but omitted the time and place where the drugs were supposedly seized. While failure to comply with the PNP Manual does not automatically invalidate the evidence, the Court found that this omission added to the uncertainty surrounding its identity and integrity.
4. The Laboratory Request Did Not State the Weight of the Drugs
Another problem appeared in the Request for Laboratory Examination.
Although the weights of the seized drugs were specified in the criminal Informations, the laboratory request did not indicate those weights.
The Supreme Court considered this omission significant because the documentation accompanying seized drugs helps establish that the items submitted for examination were the same items taken during the police operation. The missing weight information created additional doubt concerning the preservation and identification of the evidence.
5. The Prosecution Failed to Explain How the Evidence Custodian Safeguarded the Drugs
Finally, the Court examined what happened after the forensic chemist completed the laboratory examination.
The seized items were turned over to an evidence custodian for safekeeping until their presentation in court. However, the custodian's stipulated testimony merely established that he received the evidence, placed it in the evidence room, and signed the chain of custody form. It did not explain how the drugs were secured, preserved, or handled while they remained in his custody.
The Supreme Court ruled that this left a material gap in the chain of custody.
Simply showing that an evidence custodian received the items is not necessarily sufficient. The prosecution must also account for how the drugs were protected against possible tampering, substitution, or contamination.
Why Is Chain of Custody So Important in Drug Cases?
In prosecutions for illegal sale and possession of dangerous drugs, the seized substance is the corpus delicti, or the essential evidence of the offense.
Because illegal drugs can be easily substituted, contaminated, or tampered with, the prosecution must establish their identity and integrity beyond reasonable doubt.
This is why Section 21 of RA 9165 requires safeguards such as immediate inventory, photographing, mandatory insulating witnesses, and proper documentation.
In Irizumi's case, the Supreme Court found that the combined deficiencies prevented it from being certain that the drugs presented during trial were the same items allegedly seized from the accused.
The prosecution therefore failed to overcome the constitutional presumption of innocence.
Supreme Court Orders Acquittal and Immediate Release
The Supreme Court reversed the convictions and acquitted Irizumi of illegal sale and illegal possession of dangerous drugs.
It ordered his release unless he was being detained for another lawful cause.
The ruling illustrates an important principle in criminal defense: even when police officers claim to have recovered dangerous drugs, the prosecution must still prove that the evidence was properly seized, identified, preserved, and presented in court.
The presence of laboratory results, photographs, and signed inventory forms does not automatically establish an unbroken chain of custody.
Need a Criminal Defense Lawyer for an RA 9165 Drug Case?
Drug-related charges carry serious penalties, including lengthy imprisonment. A careful review of the arrest, inventory, mandatory witnesses, evidence markings, laboratory documents, and every transfer of the seized items may reveal significant weaknesses in the prosecution's case.
Cunanan Law Office provides legal representation in RA 9165 drug cases, illegal sale and possession of dangerous drugs, chain of custody violations, and other criminal defense matters in Tarlac, Pampanga, Angeles City, Clark, and anywhere in the Philippines.
Contact Cunanan Law Office today at inquiries@mpeclaw.com or call (+63) 968-679-6617 to schedule a legal consultation.