People v. Langco y Anding

FIRST DIVISION

[G.R. No. 249852. June 14, 2021.]

PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs.SEHAWI LANGCO y ANDING, A.K.A. "MACO", accused-appellant.

NOTICE

Sirs/Mesdames :

Please take notice that the Court, First Division, issued a Resolution datedJune 14, 2021which reads as follows:

"G.R. No. 249852 — PEOPLE OF THE PHILIPPINES, plaintiff-appellee, versus SEHAWI LANGCO y ANDING, a.k.a. "Maco,"accused-appellant.

This is an appeal under Section 13, Rule 124 of the Rules of Court from the Decision 1 dated January 31, 2019 issued by the Court of Appeals (CA) Third Division in CA-G.R. CR-HC No. 10291, which affirmed with modification the Consolidated Decision 2 dated November 3, 2017 of the Regional Trial Court (RTC) of Marikina City, Branch 193 finding accused-appellant Sehawi Langco y Anding, a.k.a. "Maco" (accused-appellant), guilty beyond reasonable doubt of violations of Sections 5 and 11, Article II of Republic Act (R.A.) No. 9165, 3 or the Comprehensive Dangerous Drugs Act of 2002.

Facts

Accused-appellant was charged with Sale and Possession of Dangerous Drugs under the following Informations:

Criminal Case No. 2015-4797-D-MK

That on or about the 8th day of July, 2015 in the City of Marikina, Philippines, and within the jurisdiction of this Honorable Court, the above-named accused, without being authorized by law, did then and there willfully, unlawfully, feloniously and knowingly sell to PO2 RONEL P. AGSAWA, a poseur[-]buyer, one (1) heat-sealed transparent plastic sachet containing 0.20 gram of white crystalline substance which after laboratory examination was found to be positive for METHAMPHETAMINE HYDROCHLORIDE and marked as "SAL-BB 7/8/15 with signature," a dangerous drug, in violation of the above-cited law.

CONTRARY TO LAW. 4 (Emphasis in the original)

Criminal Case No. 2015-4798-D-MK

That on or about the 8th day of July, 2015 in the City of Marikina, Philippines, and within the jurisdiction of this Honorable Court, the above-named accused, without being authorized by law, did then and there willfully, unlawfully, feloniously and knowingly have in his possession, direct control and custody, of the following items:

a. One (1) heat-sealed transparent plastic sachet containing 0.40 gram of white crystalline substance marked as "SAL-1A 7/8/15 with signature";

b. One (1) heat-sealed transparent plastic sachet containing 0.50 gram of white crystalline substance marked as "SAL-1B 7/8/15 with signature"; EcTCAD

c. One (1) heat-sealed transparent plastic sachet containing 0.20 gram of white crystalline substance marked as "SAL-1C 7/8/15 with signature";

d. One (1) heat-sealed transparent plastic sachet containing 0.50 gram of white crystalline substance marked as "SAL-1D 7/8/15 with signature";

e. One (1) heat-sealed transparent plastic sachet containing 0.80 gram of white crystalline substance marked as "SAL-1E 7/8/15 with signature";

f. One (1) heat-sealed transparent plastic sachet containing 0.21 gram of white crystalline substance marked as "SAL-1F 7/8/15 with signature";

g. One (1) heat-sealed transparent plastic sachet containing 0.24 gram of white crystalline substance marked as "SAL-1G 7/8/15 with signature";

h. One (1) heat-sealed transparent plastic sachet containing 0.32 gram of white crystalline substance marked as "SAL-1H 7/8/15 with signature";

i. One (1) heat-sealed transparent plastic sachet containing 0.20 gram of white crystalline substance marked as "SAL-1I 7/8/15 with signature";

j. One (1) heat-sealed transparent plastic sachet containing 1.75 gram[s] of white crystalline substance marked as "SAL-1J 7/8/15 with signature";

k. One (1) heat-sealed transparent plastic sachet containing 0.25 gram of white crystalline substance marked as "SAL-1K 7/8/15 with signature";

l. One (1) heat-sealed transparent plastic sachet containing 0.25 gram of white crystalline substance marked as "SAL-1L 7/8/15 with signature"; and

m. One (1) heat-sealed transparent plastic sachet containing 0.80 gram of white crystalline substance marked as "SAL-1M 7/8/15 with signature";

which after laboratory examination were found to be positive for METHAMPHETAMINE HYDROCHLORIDE, a dangerous drug, in violation of the above-cited law.

CONTRARY TO LAW. 5 (Emphasis in the original)

Upon arraignment, accused-appellant pleaded not guilty to both charges. 6 Thereafter, trial ensued.

The prosecution presented Police Officer 3 Ronel Agsawa (PO3 Agsawa) as witness. The testimonies of Police Chief Inspector Margarita M. Libres (PCI Libres), Forensic Chemist of the Philippine National Police (PNP) Eastern Police District Crime Laboratory, and Police Officer Deogracias Basang were dispensed with after the prosecution and the defense agreed to enter into stipulations on the same.

Version of the Prosecution

The evidence of the prosecution tends to prove the following events, as summarized by the CA:

In the morning of 08 July 2015, the police station of Marikina City received information from the confidential informant [(CI)] that one @ MACO, the accused-appellant, was engaged in illegal drug-trade activities. Upon verification, a buy-bust team was formed with [PO3 Agsawa] as poseur-buyer to hand over three (3) pieces of P100-peso bill as buy-bust money and SPO1 Deogracias Basang as back-up/arresting officer.

In the afternoon of the same day, the group together with the CI proceeded to the target area. PO3 Agsawa and the CI went to an alley and saw the accused-appellant in front of the store. The CI introduced PO3 Agsawa as interested to purchase methamphetamine hydrochloride commonly known as shabu, with accused-appellant who asked in turn for how much. PO3 Agsawa said P300.00 and after accused-appellant received the money, he got a black pouch from his left pocket from where he got a plastic sachet which he handed over to PO3 Agsawa. Thereafter, PO3 Agsawa executed the pre-arranged signal which led to the arrest of the accused-appellant.

PO3 Agsawa confiscated the black pouch from accused-appellant's, ([sic]) which yielded thirteen (13) plastic sachets with suspected shabu. He likewise ordered accused-appellant to bring out the contents of his pocket where he recovered the buy-bust money and some cash in the amount of P1,260.00. After recovering the items, he marked them accordingly and conducted the inventory of the seized items in the presence of the accused-appellant, a barangay kagawad, the Vice-Mayor, two (2) councilors and representative from the media with their photos taken thereat.

The accused-appellant was brought to the police station along with the seized items. PO3 Agsawa prepared the request for laboratory examination, Chain of Custody Form and together with the seized items, he brought the same to the EPD Crime Laboratory, received by [PCI Libres]. Forensic Chemist PCI Libres conducted the laboratory examination and thereafter reduced her findings by way of Physical Science Report No. MCSO-DT-131-15, that the specimens tested positive for methamphetamine hydrochloride, a dangerous drug. 7 (Citations omitted)

Version of the Defense

On the other hand, the defense presented accused-appellant as its sole witness. As summarized by the CA, the defense's version of events is as follows:

In the afternoon of 08 July 2015, while he was outside his house watching people engaged in gambling activities, some male persons approached him and introduced themselves as members of Station Anti-Illegal Drugs. They asked him if he was MACO and when he answered in the negative, he was handcuffed. The group also demanded money from him. Having nothing to give, he was brought to the police station and was detained thereafter. 8 (Citations omitted) HSAcaE

Ruling of the RTC

On November 3, 2017, the RTC rendered the Consolidated Decision, 9 the dispositive portion of which states:

WHEREFORE, premises considered, judgment is hereby rendered as follows:

In Criminal Case No. 2015-4797-D-MK, accused SEHAWI LANGCO y ANDING a.k.a. MACO, is hereby found GUILTY beyond reasonable doubt of the crime of Violation of Section 5, Article II of [R.A. No.] 9165. He is hereby sentenced to suffer the penalty of life imprisonment and the payment of a fine in the amount of five hundred thousand (Php500,000.00) pesos.

In Criminal Case No. 2015-4798-D-MK, accused SEHAWI LANGCO y ANDING a.k.a. MACO, is hereby found GUILTY beyond reasonable doubt of the crime of Violation of Section 11, Article II of [R.A. No.] 9165.

Considering that the amount of Methamphetamine Hydrochloride exceeded five (5) grams, in accordance with paragraph No. 2, Section 11, R.A. No. 9165, accused Sehawi Langco y Anding a.k.a Maco is hereby sentenced to suffer the penalty of imprisonment of twenty (20) years and one (1) day to life imprisonment and a fine in the amount of Four hundred thousand (P400,000.00) pesos.

The sachets of methamphetamine hydrochloride (shabu) confiscated from accused SEHAWI LANGCO y ANDING a.k.a. MACO, are forfeited in favor of the government and ordered disposed in accordance with law.

SO ORDERED. 10 (Emphasis in the original)

The RTC found that all the elements of both sale and possession of dangerous drugs were proven through the testimony of PO3 Agsawa and the documentary and object evidence offered by the prosecution. It likewise found that the integrity and evidentiary value of the seized drugs were preserved by the apprehending officers. 11

Ruling of the CA

On January 31, 2019, the CA rendered the assailed Decision 12 affirming the RTC Consolidated Decision, but modifying the penalty for possession of dangerous drugs in accordance with People v. Dela Rosa. 13 The dispositive portion of the CA Decision states:

WHEREFORE, premises considered, the instant Appeal is hereby DENIED. Accordingly, the Judgment dated 03 November 2017 issued by Branch 193, Regional Trial Court of Marikina City is hereby AFFIRMED but MODIFIED in that for the crime of illegal possession of shabu in violation of Section 11, Article II of Republic Act No. 9165, docketed as Criminal Case No. 2015-4798-D-MK, accused-appellant is hereby sentenced to suffer the penalty of imprisonment of twenty (20) years and one (1) day and a fine of ([sic]) in the amount of P400,000.00 pesos.

The DECISION is AFFIRMED in all other respects.

SO ORDERED. 14 (Emphasis in the original)

Issue

For resolution of the Court is the question of whether the RTC and the CA correctly convicted accused-appellant for violations of Sections 5 and 11, Article II of R.A. No. 9165.

Ruling of the Court

Accused-appellant points to several purported violations of established procedure in the police officers' handling of the items allegedly confiscated from him, resulting in significant gaps in the chain of custody.

First, he claims that the first link in the chain of custody — the seizure and marking of the dangerous drugs recovered from the accused by the apprehending officer 15 — was not established because the arresting officer marked the seized drugs with his initials and not with the officer's initials, and without indicating the time and place where the items were seized, in violation of Section 2.35 16 of the 2014 Revised PNP Manual on Anti-Illegal Drugs Operations and Investigation (PNP Manual). He also notes that the police officers failed to indicate the exact weight of the seized drugs in the Inventory of Evidence 17 and in the Chain of Custody Form, 18 in violation of Section 2.39 (a) (5) 19 of the PNP Manual.

Accused-appellant also claims that the second link in the chain of custody — the turnover of the dangerous drugs seized by the apprehending officer to the investigating officer 20 — was absolutely lacking because the drugs were never turned over by the arresting officer, PO3 Agsawa, to an investigator. Based on PO3 Agsawa's testimony 21 and the Chain of Custody Form, PO3 Agsawa directly brought the drugs to the Crime Laboratory. Accused-appellant points out that failure to turn over to an investigator is a violation of Section 2.39 (a) (8) 22 of the PNP Manual. Moreover, there is no evidence or testimony as to how the drugs were preserved or what measures were taken for safekeeping. HESIcT

The fourth or last link in the chain — the turnover and submission of the marked illegal drugs seized by the forensic chemist to the court 23 — was also not properly established, according to accused-appellant. There was no testimony or evidence on who brought the specimens to the court or how they were handled for safekeeping in transit.

Finally, accused-appellant bewails the absence of a member of the National Prosecution Service during inventory and photographing of the seized items, as well as inconsistencies in the testimony of PO3 Agsawa which accused-appellant argues are material.

To sustain a conviction for Illegal Sale of Dangerous Drugs under Section 5 of R.A. No. 9165, the prosecution must prove beyond reasonable doubt the existence of all the following elements: (a) the identity of the buyer and the seller, the object, and the consideration; and (b) the delivery of the thing sold and the payment. 24 On the other hand, the following elements are essential for a conviction for Illegal Possession of Dangerous Drugs: (a) the accused was in possession of an item or object identified as a prohibited drug; (b) such possession was not authorized by law; and (c) the accused freely and consciously possessed the said drug. 25

In both charges, the identity of the dangerous drugs in question, being the corpus delicti, must also be proven beyond reasonable doubt. This is done by proving an unbroken chain of custody of the seized drugs. The Court has said:

Apart from showing the presence of the above[-]cited elements, it is of utmost importance to likewise establish with moral certainty the identity of the confiscated drug. To remove any doubt or uncertainty on the identity and integrity of the seized drug, it is imperative to show that the substance illegally possessed and sold by the accused is the same substance offered and identified in court. This requirement is known as the chain of custody rule under R.A. No. 9165 created to safeguard doubts concerning the identity of the seized drugs.

Chain of custody means the duly recorded, authorized movements, and custody of the seized drugs at each state, from the moment of confiscation to the receipt in the forensic laboratory for examination until it is presented to the court. x x x 26 (Citations omitted)

At the outset, the Court notes that the requirements of Section 21 of R.A. No. 9165, as amended, have been complied with by the police officers. The necessary witnesses — an elective government official (there were four present in this case) and a member of the media — were present during inventory, which was done immediately after seizure. While the markings made on the items were not exactly as directed in the PNP Manual, the markings made by PO3 Agsawa using accused-appellant's initials still served the purpose of making the seized items visually and physically distinct, separating them from the corpus of all other similar or related evidence. 27 Despite the minor deviations, the prosecution was able to establish a continuous chain of custody from seizure until the confiscated drugs were subjected to qualitative examination at the crime laboratory.

However, the Court finds that there was indeed a break in the chain of custody at the fourth link — from the time after testing until the drugs were brought to the RTC. The records do not reveal any details of how the drugs were kept and who had custody thereof after the crime laboratory had concluded its testing. While the prosecution and the defense stipulated 28 on the testimony of the Forensic Chemist, PCI Libres, nothing therein touched upon the processes which were followed after she was finished with her examination. Despite the fact that PO3 Agsawa identified the 14 sachets of shabu in open court, he did not testify that he was the one who brought the sachets to the RTC and in what manner they were taken from the police station to the RTC. The utter lack of information on this link in the chain of custody casts serious doubt on the authenticity and integrity of the dangerous drugs offered in evidence.

The Court has time and again stressed the importance of establishing the fourth or final link in the chain of custody. In People v. Ubungen, 29 the Court said:

Finally, compliance with the fourth link in the chain of custody was not satisfactorily demonstrated by the prosecution. It must be recalled that the trial court dispensed with the testimony of PI Ordoño, the forensic chemist, in view of the stipulation entered into by the prosecution and the defense during the hearing of the case on 18 September 2008.

In People v. Pajarin, the Court ruled that in case of a stipulation by the parties to dispense with the attendance and testimony of the forensic chemist, it should be stipulated that the forensic chemist would have testified that he took the precautionary steps required in order to preserve the integrity and evidentiary value of the seized item, thus: (1) that the forensic chemist received the seized article as marked, properly sealed, and intact; (2) that he resealed it after examination of the content; and (3) that he placed his own marking on the same to ensure that it could not be tampered pending trial.

In this case, there is no record that the stipulations between the parties contain the aforesaid conditions.

In its Order, dated 18 September 2008, wherein it dispensed with the testimony of PI Ordoño, the trial court enumerated the stipulations agreed upon by the parties which were made the bases of the order:

In today's hearing, Public Prosecutor Bonifacio Mangibin and defense counsel Atty. Alexander Andres stipulated on the following:

1) The specimen as indicated in the Chemistry Report;

2) The findings as stated in the Chemistry Report; and

3) The due execution and genuineness of the Chemistry Report.

Clear from the foregoing is the lack of the stipulations required for the proper and effective dispensation of the testimony of the forensic chemist. While the stipulations between the parties herein may be viewed as referring to the handling of the specimen at the forensic laboratory and to the analytical results obtained, they do not cover the manner the specimen was handled before it came to the possession of the forensic chemist and after it left her possession. Absent any testimony regarding the management, storage, and preservation of the illegal drug allegedly seized herein after its qualitative examination, the fourth link in the chain of custody of the said illegal drug could not be reasonably established. 30 (Citations omitted and emphasis supplied) caITAC

In the same vein, in People v. Casilang, 31 the Court explained:

The prosecution would have completed its proof of compliance with the chain of custody procedure through the convincing and straightforward testimony of PSI Malojo-Todeño, were it not for the fact that her statement with regard to the safekeeping of the illegal drug by PO2 Manuel remained unsubstantiated. Other than PSI Malojo-Todeño's bare allegations, the prosecution failed to present clear and convincing proof that PO2 Manuel took responsibility over the illegal drug.

xxx xxx xxx

The prosecution's failure to present evidence showing the manner in which the illegal drug subject of this case was handled, stored and safeguarded by PO2 Manuel pending its presentation in court is fatal to its case. In People v. Obmiranis, We acquitted the appellant due to the failure of the key persons who handled the dangerous drug to testify on the whereabouts of the exhibit before it was offered as evidence in court. This failure casts doubt on the identity of the corpus delicti and negates the presumption of regularity in the performance of official functions. 32 (Citations omitted and emphasis supplied)

Furthermore, the records are likewise silent as to how PCI Libres herself handled and preserved the integrity of the drugs after she conducted the examination. In People v. Caringal, 33 the Court said:

More, the prosecution did not present any witness to testify on how the forensic chemist handled the specimens during laboratory examination and how the evidence custodian preserved them until they reached the trial court. Rather, it relied on the presumption of regularity in maintaining that the fourth link in the custodial chain had been sufficiently established.

In the recent cases of People v. Ubungen and People v. Victoria, the Court ruled that absent any testimony on the management, storage, and preservation of the seized illegal drug, the fourth link in the chain of custody could not be reasonably established. Too, in People v. Pajarin, the Court noted that in stipulating to dispense with the attendance of the police chemist, the parties should stipulate: 1) he received the seized article marked, properly sealed and intact; 2) he resealed it after examination of the content; 3) and he placed his own marking on the same to ensure that it could not be tampered (sic) pending trial.

Here, the prosecution failed to establish that the parties stipulated on the handling, safekeeping, and preservation of the seized items after their examination in accordance with the guidelines set forth in Ubungen and Victoria. They also failed to comply with the required stipulations on the forensic chemist's testimony in Pajarin, the parties having merely stipulated on the chemist's qualification, his receipt of the seized item, its identification and the positive result thereof. 34 (Citations omitted and emphasis supplied)

Failure to establish the fourth link in the chain of custody — indeed, failure to establish any link in the chain — is sufficient ground to acquit the accused. In People v. Plaza, 35 the Court said:

However, even if the first three (3) links may have been substantially complied with, the fourth link is where the Court takes issue.

xxx xxx xxx

It has been held that there is a gap or break in the fourth link of the chain of custody where there is absence of evidence to show how the seized shabu was handled, stored, and safeguarded pending its presentation in court. In some instances, when the stipulation failed to identify who received the shabu at the crime laboratory and who exercised custody and possession before and after it was examined, the Court similarly considered that there was a gap in the chain of custody. The instant case has stark similarities with the case of People v. Prudencio, where the Court noted:

As mentioned previously, PO1 Magora's testimony never touched upon the details on how the seized drugs were turned over to the investigating officer, nor on how it was turned over to the forensic chemist, P/Sr. Insp. Sta. Maria, for laboratory examination. The only pieces of evidence representing the third link in the chain consisted of the letter-requests for laboratory examination and for drug test, and the corresponding chemistry reports issued by P/Sr. Insp. Sta. Maria.

As to the fourth link, when P/Sr. Insp. Sta. Maria was called to the witness stand, the prosecution and the defense decided to enter into a stipulation regarding what P/Sr. Insp. Sta. Maria would be testifying on if he were presented. Yet, all they stipulated was that he would identify the request for laboratory examination, request for drug test, the subject sachets of shabu, and the chemistry reports. ICHDca

These pieces of evidence failed to identify the person who personally brought the seized shabu to the Bulacan Provincial Crime Laboratory Office. It also failed to identify who received the shabu at the crime laboratory and who exercised custody and possession before and after it was examined. Neither was there evidence to show how the seized shabu were handled, stored, and safeguarded pending its presentation in court.

Notably, Section 6, paragraph 8 of Dangerous Drugs Board Regulation No. 2, Series of 2003 requires laboratory personnel to document the chain of custody each time a specimen is handled or transferred until the specimen is disposed; it also requires the identification of the individuals participating in the chain. The records are silent regarding compliance with this regulation.

Simply put, serious lapses in the handling of the seized shabu as well as the evidentiary gaps or breaks in the chain of custody are fatal to the prosecution's cause. In effect, the prosecution failed to fully prove the elements of the crimes charged, creating a reasonable doubt on the criminal liability of the accused.

xxx xxx xxx

Even a painstaking review of the records and transcripts yields no results as to information on the chain of custody between the time PDEA Agent Subang confiscated the subject sachet of drugs up to the time it was presented in court. Though the Chain of Custody Document was presented during PSInsp. Signar's testimony, the same was not identified by any witness. While the document contains the signatures of a certain PO1 Randy Dispo and another recipient of the sachet for "safekeeping," the Court is left to surmise on whether the proper procedure was followed during this intervening period. Clearly, there was no identification of all persons who handled the sachet nor was there testimony as to every relevant link in the chain, nor a showing that all possible safeguards were done by the law enforcement agents to protect the integrity of the evidence, as mandated by law and jurisprudence. This goes against the settled doctrines of this Court requiring these pieces of evidence in the prosecution of drug cases. 36 (Citations and underscoring omitted, and emphasis supplied)

Similarly, in this case, the utter lack of details on the condition and handling of the seized drugs from the period after examination until the same were brought to the trial court results in a gap in the chain of custody of the seized drugs, casting serious doubt on the identity of the corpus delicti. Consistent with law and jurisprudence, the Court is constrained to acquit accused-appellant of the crimes charged.

WHEREFORE, premises considered, the appeal is hereby GRANTED. The Decision dated January 31, 2019 issued by the Court of Appeals Third Division in CA-G.R. CR-HC No. 10291 is hereby REVERSED and SET ASIDE. Accordingly, Sehawi Langco y Anding, a.k.a "Maco," is ACQUITTED of the crimes charged on the ground of reasonable doubt, and is ORDERED IMMEDIATELY RELEASED from detention unless he is being lawfully held for another cause. Let entry of judgment be issued immediately.

Let a copy of this Resolution be furnished the Director General of the Bureau of Corrections, Muntinlupa City, for immediate implementation. Said Director General is ordered to report to this Court within five (5) working days from receipt of this Resolution the action he has taken.

SO ORDERED." (Zalameda, J., no part; Perlas-Bernabe, J., designated as additional Member per Raffle dated May 12, 2021.)

By authority of the Court:

(SGD.) LIBRADA C. BUENADivision Clerk of Court

By:

MARIA TERESA B. SIBULODeputy Division Clerk of Court

 

Footnotes

1. CA rollo, pp. 110-124. Penned by Associate Justice Rodil V. Zalameda (now a Member of the Court) and concurred in by Associate Justices Fernanda Lampas Peralta and Henri Jean Paul B. Inting (now also Member of the Court).

2.Id. at 57-68. Penned by Judge Alice C. Gutierrez.

3. Approved on June 7, 2002.

4. Records, p. 2.

5.Id. at 4-5.

6.Id. at 32-33.

7. CA rollo, pp. 114-115.

8.Id. at 115-116.

9.Supra note 2.

10.Id. at 68.

11.Id. at 67.

12.Supra note 1.

13. G.R. No. 185166, January 26, 2011, 640 SCRA 635.

14. CA rollo, p. 123.

15.People v. Omamos, G.R. No. 223036, July 10, 2019.

16. Section 2.35 states: "The Seizing Officer must mark the evidence with his initials indicating therein the date, time and place where the evidence was found/recovered or seized."

17. Folder of Exhibits, p. 5.

18.Id. at 6.

19. Section 2.39 (a) (5) states: "All the illegal drugs and/or CPEC's shall be properly marked for identification, weighed when possible or counted, sealed, packed and labeled. The exact weight of the illegal drugs seized or recovered should be recorded in the inventory and Chain of Custody Forms or Evidence Vouchers."

20.People v. Omamos, supra note 15.

21. Transcript of Stenographic Notes, May 3, 2017.

22. Section 2.39 (a) (8) states: "All pieces of drug evidence shall be turned over by the Seizing Officer to the Investigator-On-Case who shall submit the same to the PDEA Laboratory Service or PNP Crime Laboratory for examination. All the phases of turn over of evidence must have corresponding receipts to show continuance of chain of custody."

23.People v. Omamos, supra note 15.

24.People v. Crispo, G.R. No. 230065, March 14, 2018, 859 SCRA 356, 369.

25.Id.

26.People v. Bangcola, G.R. No. 237802, March 18, 2019, 897 SCRA 330, 344-345.

27.People v. Castillo, G.R. No. 238339, August 7, 2019, p. 12.

28. RTC Order dated February 4, 2016, records, pp. 49-54.

29. G.R. No. 225497, July 23, 2018, 873 SCRA 172.

30.Id. at 186-187.

31. G.R. No. 242159, February 5, 2020.

32.Id. at 14-15.

33. G.R. No. 236585, December 5, 2019 (Unsigned Resolution).

34.Id.

35. G.R. No. 235467, August 20, 2018, 878 SCRA 231.

36.Id. at 250, 254-257.