Professional Documents
Culture Documents
Ruel Tuano y Hernandez vs. People of The Philippines 2016
Ruel Tuano y Hernandez vs. People of The Philippines 2016
Summary: Law enforcers should not trifle with the legal requirement to
ensure the integrity in the chain of custody of seized dangerous drugs and
drug paraphernalia. This is especially true when only a miniscule amount of
dangerous drugs is alleged to have been taken from the accused.
Facts:
PO2 Santos and PO2 Eduardo Bernardo were conducting surveillance patrol, they saw petitioner waving
a small plastic sachet containing a white crystalline substance they suspected to be "shabu." PO2 Santos
approached petitioner, introduced himself as a police officer, and inquired about the sachet. PO2 Santos
confiscated the sachet and brought petitioner to the police station for investigation. He marked the
plastic sachet with the initials "RHT" then turned it over to police investigator PO2 Llorete. They
prepared the documents required for filing a case. The confiscated substance brought to the crime
laboratory yielded positive for methylamphetamine hydrochloride.
Petitioner countered that he was standing along the alley of Kahilum I, Pandacan, Manila with his
companion "Tek-tek" when police officers arrived to arrest a "Len-len." "Len-len" escaped and the police
officers arrested them instead.
When petitioner asked for the reason of his arrest, he was told it was for buying "shabu." Petitioner
claimed he was just standing there, but the police officers handcuffed him and brought him to the police
station.
Issue: Whether or not the none compliance of Sec 21 of RA 9165 validates the confiscation of drugs?
Held: No. While this Court has ruled that "the failure of the policemen to make a physical inventory and
to photograph the confiscated items are not fatal to the prosecution's cause," more recent cases
highlight the need for strict compliance with the legal requirements to protect the integrity of the chain
of custody, more so when the miniscule quantity of the confiscated substance—0.064 gram, in this case
—underscores the need for exacting compliance with Section 21.
Non-compliance with the requirements under Section 21 creates uncertainty on the identity and
integrity of the confiscated substance. It casts doubt on the guilt of the accused.