SC ends drug accused’s 8-year wrongful jail time

In People v. Narvas (G.R. No. 241254, July 08, 2019), the prosecution miserably failed to provide justifiable grounds for the apprehending team's deviation from the rules laid down in Section 21 of RA 9165, also known as the chain of custody rule. The integrity and evidentiary value of the corpus delicti have thus been seriously compromised. In light of this, accused-appellant Narvas must perforce be and was in fact acquitted.

Despite the blatant disregard of the mandatory requirements provided under RA 9165 and the patent unreliability and lack of credibility of the prosecution's witnesses, accused-appellant Narvas was been made to suffer incarceration for eight (8) years. While the Supreme Court already reversed this grave injustice by ordering the immediate release of accused-appellant Narvas, there is truth in the time-honored precept that justice delayed is justice denied. Such an injustice must not be repeated.

In this connection, the Supreme Court sternly reminded the trial and appellate courts to exercise extra vigilance in trying drug cases, and directed the Philippine National Police to conduct an investigation on this incident and other similar cases, lest an innocent person be made to suffer the unusually severe penalties for drug offenses.

The Court likewise exhorted the prosecutors to diligently discharge their onus to prove compliance with the provisions of Sectional of RA 9165, as amended, and its implementing rules and regulations (IRRs), which is fundamental in preserving the integrity and evidentiary value of the corpus delicti.To the mind of the Court, the procedure outlined in Section 21 is straightforward and easy to comply with. In the presentation of evidence to prove compliance therewith, the prosecutors are enjoined to recognize any deviation from the prescribed procedure and provide the explanation therefor as dictated by available evidence. Compliance with Section 21 being integral to every conviction, the appellate court, this Court included, is at liberty to review the records of the case to satisfy itself that the required proof has been adduced by the prosecution whether the accused has raised, before the trial or appellate court, any issue of non-compliance. If deviations are observed and no justifiable reasons are provided, the conviction must be overturned, and the innocence of the accused affirmed.[1]

The Court believes that the menace of illegal drugs must be curtailed with resoluteness and determination. Our Constitution declares that the maintenance of peace and order, the protection of life, liberty, and property, and the promotion of the general welfare are essential for the enjoyment by all the people of the blessings of democracy.[2]

Nevertheless, by thrashing basic constitutional rights as a means to curtail the proliferation of illegal drugs, instead of protecting the general welfare, oppositely, the general welfare is viciously assaulted. In other words, by disregarding the Constitution, the war on illegal drugs becomes a self- defeating and self-destructive enterprise. A battle waged against illegal drugs that tramples on the rights of the people is not a war on drugs. It is a war against the people.

The sacred and indelible right to due process enshrined under our Constitution, fortified further under statutory law, should not be sacrificed for the sheer sake of convenience and expediency. Otherwise, the rule of men shall overtake the rule of law. In a democracy, this cannot and should not be permitted, not while this Court sits.

[1] See People v. Jugo, G.R. No. 231792, January 29, 2018, accessed at < http://elibrary.judiciary.gov.ph >.
[2] Constitution, Art. II, Sec. 5.