PEOPLE OF THE PHILIPPINES vsNOAH

PEOPLE OF THE PHILIPPINES vs.
LINA ACHIENG NOAH

G.R. No. 228880| March 06, 2019 | Third Division | LEONEN, J.:
DOCTRINE: The chain of custody ensures that there would be no unnecessary doubts
concerning the identity of the evidence.
FACTS:
Noah was charged of violation of Article II, Section 5 of Republic Act No. 9165.
Customs Examiner Marius Landicho (Landicho) testified that at the Ninoy Aquino International
Airport Terminal 1, Noah, a Kenyan national who arrived from Kenya via Dubai, approached
Lane Number Five (5) of the Customs Arrival Area. He asked her to present her passport and
Baggage Declaration. Landicho then asked her to open her luggage Upon inspection, Landicho
noticed that while the smaller bag was empty, its flap was hard and thick and its sidings were
suspiciously padded and had tampered stitches. Noting that it was odd for such a bag to be
hard, Landicho asked Noah to follow him to the exclusion room for further examination of her
luggage. The inspection revealed seven (7) rectangular packages, wrapped in vacuum-sealed
aluminum foil, on which Landicho affixed his initials and signature. In Noah's presence, Special
Agent I Noble and Landicho inspected the luggage and found hidden compartments. Inside were
compressed foil packs containing white crystalline substance. Upon testing samples using
Marquis Reagent No. 2, the white crystalline substance yielded positive for methamphetamine
hydrochloride or shabu. Special Agent I Noble added that before Noah's arrest, he asked her if
she could understand English. When she said yes, he apprised her of her Miranda rights.
Corroborating Landicho's account, Special Agent I Noble further testified that they conducted an
inventory of the seized items in the presence of Noah, an elective official, Prosecutor Rillera, and
Fabroa. In addition, pictures showing Noah with Landicho and other witnesses were taken during
the field-testing, marking, and inventory. In her defense, Noah denied transporting the illegal
drugs, she stresses that the chain of custody in handling the evidence against her had gaps, which
raise serious doubts on the authenticity of the seized shabu. She argues that the integrity and
evidentiary value of the packages recovered from her were not preserved.
The Regional Trial Court found Noah guilty beyond reasonable doubt of the crime
charged. the Court of Appeals denied the Appeal and affirmed Noah's conviction.
ISSUE:
Did the prosecution establish the unbroken chain of custody of the drug seized from
accused-appellant?
RULING:
Yes. Proof of ownership of the dangerous drugs seized is immaterial. What is important
is that the prosecution proves the act of transporting as well as the identity and integrity of the
seized drugs. This is because the confiscated drug is the corpus delicti of the crime. Since it is
not readily identifiable by sight or touch and may be easily tampered with, its preservation is
paramount. The chain of custody ensures that there would be no unnecessary doubts concerning
the identity of the evidence. Compliance with the chain of custody requirements under Section
21 ensures the integrity of the seized items. In contrast, noncompliance tarnishes the credibility
of the corpus delicti, on which prosecutions under the Comprehensive Dangerous Drugs Act are
based.
Here, the prosecution proved beyond reasonable doubt that accused appellant was indeed
transporting the illegal drugs. Although she had initially denied ownership of the luggage and
illegal drugs found, accused appellant's claim is disputed by the evidence on record. This Court
is convinced that the apprehending officers have complied with the requirements under Section
21. Based on the records, there was an unbroken chain of custody of the seized shabu from the
time of its discovery up to its presentation in court. The prosecution established that in the
exclusion room, Landicho continued inspecting the luggage before airport officers, government
agents, and accused-appellant herself. There were even pictures showing that accused-appellant
was present during the field test, marking, and inventory of the seized items.
Contrary to accused-appellant's claim, Landicho properly marked the seized shabu. Both the
Court of Appeals and the trial court found that the Inventory Report had confirmed that members
of the Customs Task Force, Anti-Narcotics Group, Fabroa, Barangay Councilor Bajada, and
Prosecutor Rillera witnessed the marking and inventory proceedings. Clearly, there were no
lapses in the disposition and handling of the seized shabu to even prompt the relaxation of the
procedure under Section 21. The prosecution complied with the standard in handling the
evidence and in establishing the chain of custody. Indeed, it proved beyond reasonable doubt that
accused-appellant is guilty of illegally transporting 5,941.9 grams of shabu as penalized under
Section 5 of the Comprehensive Dangerous Drugs Act.

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PEOPLE OF THE PHILIPPINES vs.

LINA ACHIENG NOAH

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