Lawyerly

GR No. 188698

2015-07-22

BRION, J.

Thus, to remove any doubt on the identity and integrity of the seized drug, evidence must definitely show that the illegal drug presented in court is the same illegal drug actually recovered from the accused-appellant.[11] It is in this respect that the prosecution failed.

GR No. 184789

2015-02-23

PEOPLE v. BEVERLY ALAGARME Y CITOY

BERSAMIN, J.

The last paragraph of Section 21 (a), Article II of the IRR of Republic Act No. 9165 provides a saving mechanism to ensure that not every case of non-compliance with the safeguards to preserve the chain of custody will irretrievably prejudice the Prosecution's case against the accused. However, in order for such saving mechanism to apply, the Prosecution must first recognize the lapse or lapses in the prescribed procedures and then explain the lapse or lapses.[45] Here, however, the Prosecution did not bother to show that a media representative, DOJ representative or elected public official had been notified of the buy-bust operation or, assuming that the DOJ representative or public official had been so priorly informed, the lawmen did not explain why none of such representatives was around to witness the actual marking of the evidence. Indeed, the Prosecution did not even try to show that the application of the saving mechanism provided in Section 21 (a), Article II of the IRR of Republic Act No. 9165 would be justified. Under the circumstances, the identification of the seized evidence in court during the trial became ambiguous and unreliable, rendering the proof of the links in the chain of custody of the corpus delicti unworthy of belief.

GR No. 192432

2014-06-23

PEOPLE v. LARRY MENDOZA Y ESTRADA

BERSAMIN, J.

The last paragraph of Section 21(1) of the IRR of RA No. 9165 expressly provides a saving mechanism to the effect that not every case of non-compliance with the statutory requirements for the physical inventory and photograph of the dangerous drugs being made "in the presence of the accused or the person/s from whom such items were confiscated and/or seized, or his/her representative or counsel, a representative from the media and the Department of Justice (DOJ), and any elected public official who shall be required to sign the copies of the inventory and be given a copy thereof" would prejudice the State's case against the accused. But in order for that saving mechanism to apply, and thus save the day for the State's cause, the Prosecution must have to recognize first the lapse or lapses, and then credibly explain them.[21]

GR No. 190177

2014-06-11

PEOPLE v. VIVIAN BULOTANO Y AMANTE

PEREZ, J.

In the chain of custody, the marking immediately after seizure is the starting point in the custodial link. Thereafter, the specimen shall undergo different processes and will inevitably be passed on to different persons. Thus, it is vital that there be an unbroken link in the chain to obviate switching, "planting," or contamination of evidence,[24] a fortiori, to segregate the marked evidence from the corpus of all other similar and related evidence from the time they are seized from the accused until they are disposed of at the end of the criminal proceedings.[25]

GR No. 184758

2014-04-21

PEOPLE v. SONNY SABDULA Y AMANDA

BRION, J.

Thus, to remove any doubt or uncertainty on the identity and integrity of the seized drug, evidence must definitely show that the illegal drug presented in court is the same illegal drug actually recovered from the accused-appellant; otherwise, the prosecution for possession or for drug pushing under RA No. 9165 fails.[17]

GR No. 188653

2014-01-29

LITO LOPEZ v. PEOPLE

PEREZ, J.

In the prosecution of drug cases, it is of paramount importance that the existence of the drug, the corpus delicti of the crime, be established beyond doubt. To successfully prosecute a case involving illegal drugs, the identity and integrity of the corpus delicti must definitely be shown to have been preserved. This requirement necessarily arises from the illegal drug's unique characteristic that renders it indistinct, not readily identifiable, and easily open to tampering, alteration or substitution either by accident or otherwise. Thus, to remove any doubt or uncertainty on the identity and integrity of the seized drug, evidence must definitely show that the illegal drug presented in court is the same illegal drug actually recovered from the accused-petitioner.[13]

GR No. 203028

2014-01-15

PEOPLE v. JOSELITO BERAN Y ZAPANTA

REYES, J.

In People v. Morales,[32] we acquitted the accused due to the failure of the buy-bust team to photograph and inventory the seized items or to give justifiable grounds for their non-observance of the required procedures. In People v. Garcia,[33] the accused was acquitted because "no physical inventory was ever made, and no photograph of the seized items was taken under the circumstances required by R.A. No. 9165 and its implementing rules."[34] We issued the same ruling in Bondad, Jr. v. People,[35] where the police without justifiable grounds did not inventory or photograph the seized items. We reiterated the same ruling in People v. Gutierrez,[36] People v. Denoman,[37] People v. Partoza,[38] People v. Robles,[39] and People v. dela Cruz.[40] In all these cases, we stressed the importance of complying with the required mandatory procedures in Section 21 of R.A. No. 9165 concerning the preservation of the chain of custody of confiscated drugs in a buy-bust operation.

GR No. 191071

2013-08-28

PEOPLE v. ROGELIA JARDINEL PEPINO-CONSULTA

LEONARDO-DE CASTRO, J.

We held in People v. Hernandez[35] that "[t]o secure a conviction for illegal sale of shabu, the following essential elements must be established: (1) the identity of the buyer and the seller, the object of the sale and the consideration; and (2) the delivery of the thing sold and the payment thereof." Furthermore, we explained in People v. Denoman[36] that:A successful prosecution for the sale of illegal drugs requires more than the perfunctory presentation of evidence establishing each element of the crime: the identities of the buyer and seller, the transaction or sale of the illegal drug and the existence of the corpus delicti. In securing or sustaining a conviction under RA No. 9165, the intrinsic worth of these pieces of evidence, especially the identity and integrity of the corpus delicti, must definitely be shown to have been preserved. This requirement necessarily arises from the illegal drug's unique characteristic that renders it indistinct, not readily identifiable, and easily open to tampering, alteration or substitution either by accident or otherwise. Thus, to remove any doubt or uncertainty on the identity and integrity of the seized drug, evidence must definitely show that the illegal drug presented in court is the same illegal drug actually recovered from the accused-appellant; otherwise, the prosecution for possession or for drug pushing under RA No. 9165 fails. (Citations omitted.)

GR No. 182417

2013-04-03

PEOPLE v. ALBERTO GONZALES Y SANTOS

BERSAMIN, J.

These provisions obviously demand strict compliance, for only by such strict compliance may be eliminated the grave mischiefs of planting or substitution of evidence and the unlawful and malicious prosecution of the weak and unwary that they are intended to prevent. Such strict compliance is also consistent with the doctrine that penal laws shall be construed strictly against the Government and liberally in favor of the accused.[13]

GR No. 181042

2012-11-26

PEOPLE v. SAMIN ZAKARIA Y MAKASULAY

BERSAMIN, J.

The last paragraph of Section 21 (a) of the IRR, supra, contains a saving proviso to the effect that "non-compliance with these requirements under justifiable grounds, as long as the integrity and the evidentiary value of the seized items are properly preserved by the apprehending officer/team, shall not render void and invalid such seizures of and custody over said items." But in order for the saving proviso to apply, the Prosecution must first recognize and explain the lapse or lapses in procedure committed by the arresting lawmen.[51] That did not happen here, because the Prosecution neither recognized nor explained the lapses. Even conceding, for instance, that the PDEA Regional Office contacted and informed the media about the buy-bust operation, we wonder why the media representative or the barangay official did not witness the actual marking of the evidence and why the representative and barangay official signed the certificate of inventory sans the presence of the accused or his representatives. In that respect, the Prosecution offered no explanation at all.

GR No. 199735

2012-10-24

PEOPLE v. AISA MUSA Y PINASILO

VELASCO JR., J.

At this juncture, We reiterate that the essence of the chain of custody rule is to ensure that the dangerous drug presented in court as evidence against the accused is the same dangerous drug recovered from his or her possession.[27] As explained in Castro v. People:[28]

GR No. 173794

2012-01-18

PEOPLE v. DARWIN RELATO Y AJERO

BERSAMIN, J.

Under the foregoing rules, the marking immediately after seizure is the starting point in the custodial link, because succeeding handlers of the prohibited drugs or related items will use the markings as reference. It further serves to segregate the marked evidence from the corpus of all other similar and related evidence from the time they are seized from the accused until they are disposed of at the end of the criminal proceedings, obviating switching, "planting," or contamination of evidence.[11] It is crucial in ensuring the integrity of the chain of custody, which is defined in Section 1(b) of Dangerous Drugs Board Regulation No. 1, Series of 2002,[12] thus: b. "Chain of Custody" means the duly recorded authorized movements and custody of seized drugs or controlled chemicals or plant sources of dangerous drugs or laboratory equipment of each stage, from the time of seizure/confiscation to receipt in the forensic laboratory to safekeeping to presentation in court for destruction. Such record of movements and custody of seized item shall include the identity and signature of the person who held temporary custody of the seized item, the date and time when such transfer of custody were made in the course of safekeeping and use in court as evidence, and the final disposition;

GR No. 189980

2011-04-06

PEOPLE v. ALBERTO BACUS ALCUIZAR

PEREZ, J.

The dangerous drug itself, the shabu in this case, constitutes the very corpus delicti of the offense and in sustaining a conviction under Republic Act No. 9165, the identity and integrity of the corpus delicti must definitely be shown to have been preserved. This requirement necessarily arises from the illegal drug's unique characteristic that renders it indistinct, not readily identifiable, and easily open to tampering, alteration or substitution either by accident or otherwise. Thus, to remove any doubt or uncertainty on the identity and integrity of the seized drug, evidence must definitely show that the illegal drug presented in court is the same illegal drug actually recovered from the accused-appellant; otherwise, the prosecution for possession under Republic Act No. 9165 fails.[18]

GR No. 185715

2011-01-19

PEOPLE v. ERLINDA CAPUNO Y TISON

BRION, J.

We had the same rulings in People v. Gutierrez,[37] People v. Denoman,[38] People v. Partoza,[39] People v. Robles,[40] and People v. dela Cruz,[41] where we emphasized the importance of complying with the required procedures under Section 21 of R.A. No. 9165.

GR No. 185378

2010-09-27

PEOPLE v. JENNEFER CARIN Y DONOGA

CARPIO MORALES, J.

In a prosecution for illegal sale of a prohibited drug, the prosecution must prove the following elements: (1) the identity of the buyer and the seller, the object, and the consideration; and (2) the delivery of the thing sold and the payment therefor. All these require evidence that the sale transaction transpired, coupled with the presentation in court of the body or substance of the crime that establishes that a crime has actually been committed.[19] Failure to comply with Section 21, paragraph (1) of Article II of RA No. 9165 and its implementing rules results, in certain cases such as in the present one, in failure to establish the existence of the crime.[20]

GR No. 187741

2010-08-08

PEOPLE v. PETER M. CAMPOMANES

MENDOZA, J.

Although Section 21(1) of R.A. No. 9165 mandates that the apprehending team must immediately conduct a physical inventory of the seized items and photograph them, non-compliance with said section 21 is not fatal as long as there is a justifiable ground therefor, and as long as the integrity and the evidentiary value of the confiscated/seized items are properly preserved by the apprehending team.[27] Thus, the prosecution must demonstrate that the integrity and evidentiary value of the evidence seized have been preserved.[28]

GR No. 178202

2010-05-14

PEOPLE v. NORMAN SITCO

VELASCO JR., J.

Although the non-presentation of some of the witnesses who can attest to an unbroken chain of custody of evidence may, in some instances, be excused, there should be a justifying factor for the prosecution to dispense with their testimonies.[27] In People v. Denoman,[28] the Court discussed the saving mechanism provided by Sec. 21(a), Article II of the Implementing Rules and Regulations of RA 9165.[29] Denoman explains that the aforementioned provision contains a saving mechanism to ensure that not every case of non-compliance will permanently prejudice the prosecution's case. The saving mechanism applies when the prosecution recognizes and explains the lapse or lapses in the prescribed procedures.[30] In this case, the prosecution did not even acknowledge and discuss the reasons for the missing links in the chain.

GR No. 174198

2010-01-19

PEOPLE v. ZAIDA KAMAD Y AMBING

BRION, J.

We applied this ruling in People v. Garcia,[27] People v. Gum-Oyen,[28] People v. Denoman[29] and People v. Coreche[30] where we recognized the following links that must be established in the chain of custody in a buy-bust situation: first, the seizure and marking, if practicable, of the illegal drug recovered from the accused by the apprehending officer; second, the turnover of the illegal drug seized by the apprehending officer to the investigating officer; third, the turnover by the investigating officer of the illegal drug to the forensic chemist for laboratory examination; and fourth, the turnover and submission of the marked illegal drug seized from the forensic chemist to the court.

	GR No. 188698 2015-07-22	PEOPLE v. SONIA BERNEL NUARIN BRION, J.
Thus, to remove any doubt on the identity and integrity of the seized drug, evidence must definitely show that the illegal drug presented in court is the same illegal drug actually recovered from the accused-appellant.[11] It is in this respect that the prosecution failed.
	GR No. 184789 2015-02-23	PEOPLE v. BEVERLY ALAGARME Y CITOY BERSAMIN, J.
The last paragraph of Section 21 (a), Article II of the IRR of Republic Act No. 9165 provides a saving mechanism to ensure that not every case of non-compliance with the safeguards to preserve the chain of custody will irretrievably prejudice the Prosecution's case against the accused. However, in order for such saving mechanism to apply, the Prosecution must first recognize the lapse or lapses in the prescribed procedures and then explain the lapse or lapses.[45] Here, however, the Prosecution did not bother to show that a media representative, DOJ representative or elected public official had been notified of the buy-bust operation or, assuming that the DOJ representative or public official had been so priorly informed, the lawmen did not explain why none of such representatives was around to witness the actual marking of the evidence. Indeed, the Prosecution did not even try to show that the application of the saving mechanism provided in Section 21 (a), Article II of the IRR of Republic Act No. 9165 would be justified. Under the circumstances, the identification of the seized evidence in court during the trial became ambiguous and unreliable, rendering the proof of the links in the chain of custody of the corpus delicti unworthy of belief.
	GR No. 192432 2014-06-23	PEOPLE v. LARRY MENDOZA Y ESTRADA BERSAMIN, J.
The last paragraph of Section 21(1) of the IRR of RA No. 9165 expressly provides a saving mechanism to the effect that not every case of non-compliance with the statutory requirements for the physical inventory and photograph of the dangerous drugs being made "in the presence of the accused or the person/s from whom such items were confiscated and/or seized, or his/her representative or counsel, a representative from the media and the Department of Justice (DOJ), and any elected public official who shall be required to sign the copies of the inventory and be given a copy thereof" would prejudice the State's case against the accused. But in order for that saving mechanism to apply, and thus save the day for the State's cause, the Prosecution must have to recognize first the lapse or lapses, and then credibly explain them.[21]
	GR No. 190177 2014-06-11	PEOPLE v. VIVIAN BULOTANO Y AMANTE PEREZ, J.
In the chain of custody, the marking immediately after seizure is the starting point in the custodial link. Thereafter, the specimen shall undergo different processes and will inevitably be passed on to different persons. Thus, it is vital that there be an unbroken link in the chain to obviate switching, "planting," or contamination of evidence,[24] a fortiori, to segregate the marked evidence from the corpus of all other similar and related evidence from the time they are seized from the accused until they are disposed of at the end of the criminal proceedings.[25]
	GR No. 184758 2014-04-21	PEOPLE v. SONNY SABDULA Y AMANDA BRION, J.
Thus, to remove any doubt or uncertainty on the identity and integrity of the seized drug, evidence must definitely show that the illegal drug presented in court is the same illegal drug actually recovered from the accused-appellant; otherwise, the prosecution for possession or for drug pushing under RA No. 9165 fails.[17]
	GR No. 188653 2014-01-29	LITO LOPEZ v. PEOPLE PEREZ, J.
In the prosecution of drug cases, it is of paramount importance that the existence of the drug, the corpus delicti of the crime, be established beyond doubt. To successfully prosecute a case involving illegal drugs, the identity and integrity of the corpus delicti must definitely be shown to have been preserved. This requirement necessarily arises from the illegal drug's unique characteristic that renders it indistinct, not readily identifiable, and easily open to tampering, alteration or substitution either by accident or otherwise. Thus, to remove any doubt or uncertainty on the identity and integrity of the seized drug, evidence must definitely show that the illegal drug presented in court is the same illegal drug actually recovered from the accused-petitioner.[13]
	GR No. 203028 2014-01-15	PEOPLE v. JOSELITO BERAN Y ZAPANTA REYES, J.
In People v. Morales,[32] we acquitted the accused due to the failure of the buy-bust team to photograph and inventory the seized items or to give justifiable grounds for their non-observance of the required procedures. In People v. Garcia,[33] the accused was acquitted because "no physical inventory was ever made, and no photograph of the seized items was taken under the circumstances required by R.A. No. 9165 and its implementing rules."[34] We issued the same ruling in Bondad, Jr. v. People,[35] where the police without justifiable grounds did not inventory or photograph the seized items. We reiterated the same ruling in People v. Gutierrez,[36] People v. Denoman,[37] People v. Partoza,[38] People v. Robles,[39] and People v. dela Cruz.[40] In all these cases, we stressed the importance of complying with the required mandatory procedures in Section 21 of R.A. No. 9165 concerning the preservation of the chain of custody of confiscated drugs in a buy-bust operation.
	GR No. 191071 2013-08-28	PEOPLE v. ROGELIA JARDINEL PEPINO-CONSULTA LEONARDO-DE CASTRO, J.
We held in People v. Hernandez[35] that "[t]o secure a conviction for illegal sale of shabu, the following essential elements must be established: (1) the identity of the buyer and the seller, the object of the sale and the consideration; and (2) the delivery of the thing sold and the payment thereof." Furthermore, we explained in People v. Denoman[36] that:A successful prosecution for the sale of illegal drugs requires more than the perfunctory presentation of evidence establishing each element of the crime: the identities of the buyer and seller, the transaction or sale of the illegal drug and the existence of the corpus delicti. In securing or sustaining a conviction under RA No. 9165, the intrinsic worth of these pieces of evidence, especially the identity and integrity of the corpus delicti, must definitely be shown to have been preserved. This requirement necessarily arises from the illegal drug's unique characteristic that renders it indistinct, not readily identifiable, and easily open to tampering, alteration or substitution either by accident or otherwise. Thus, to remove any doubt or uncertainty on the identity and integrity of the seized drug, evidence must definitely show that the illegal drug presented in court is the same illegal drug actually recovered from the accused-appellant; otherwise, the prosecution for possession or for drug pushing under RA No. 9165 fails. (Citations omitted.)
	GR No. 182417 2013-04-03	PEOPLE v. ALBERTO GONZALES Y SANTOS BERSAMIN, J.
These provisions obviously demand strict compliance, for only by such strict compliance may be eliminated the grave mischiefs of planting or substitution of evidence and the unlawful and malicious prosecution of the weak and unwary that they are intended to prevent. Such strict compliance is also consistent with the doctrine that penal laws shall be construed strictly against the Government and liberally in favor of the accused.[13]
	GR No. 181042 2012-11-26	PEOPLE v. SAMIN ZAKARIA Y MAKASULAY BERSAMIN, J.
The last paragraph of Section 21 (a) of the IRR, supra, contains a saving proviso to the effect that "non-compliance with these requirements under justifiable grounds, as long as the integrity and the evidentiary value of the seized items are properly preserved by the apprehending officer/team, shall not render void and invalid such seizures of and custody over said items." But in order for the saving proviso to apply, the Prosecution must first recognize and explain the lapse or lapses in procedure committed by the arresting lawmen.[51] That did not happen here, because the Prosecution neither recognized nor explained the lapses. Even conceding, for instance, that the PDEA Regional Office contacted and informed the media about the buy-bust operation, we wonder why the media representative or the barangay official did not witness the actual marking of the evidence and why the representative and barangay official signed the certificate of inventory sans the presence of the accused or his representatives. In that respect, the Prosecution offered no explanation at all.
	GR No. 199735 2012-10-24	PEOPLE v. AISA MUSA Y PINASILO VELASCO JR., J.
At this juncture, We reiterate that the essence of the chain of custody rule is to ensure that the dangerous drug presented in court as evidence against the accused is the same dangerous drug recovered from his or her possession.[27] As explained in Castro v. People:[28]
	GR No. 173794 2012-01-18	PEOPLE v. DARWIN RELATO Y AJERO BERSAMIN, J.
Under the foregoing rules, the marking immediately after seizure is the starting point in the custodial link, because succeeding handlers of the prohibited drugs or related items will use the markings as reference. It further serves to segregate the marked evidence from the corpus of all other similar and related evidence from the time they are seized from the accused until they are disposed of at the end of the criminal proceedings, obviating switching, "planting," or contamination of evidence.[11] It is crucial in ensuring the integrity of the chain of custody, which is defined in Section 1(b) of Dangerous Drugs Board Regulation No. 1, Series of 2002,[12] thus: b. "Chain of Custody" means the duly recorded authorized movements and custody of seized drugs or controlled chemicals or plant sources of dangerous drugs or laboratory equipment of each stage, from the time of seizure/confiscation to receipt in the forensic laboratory to safekeeping to presentation in court for destruction. Such record of movements and custody of seized item shall include the identity and signature of the person who held temporary custody of the seized item, the date and time when such transfer of custody were made in the course of safekeeping and use in court as evidence, and the final disposition;
	GR No. 189980 2011-04-06	PEOPLE v. ALBERTO BACUS ALCUIZAR PEREZ, J.
The dangerous drug itself, the shabu in this case, constitutes the very corpus delicti of the offense and in sustaining a conviction under Republic Act No. 9165, the identity and integrity of the corpus delicti must definitely be shown to have been preserved. This requirement necessarily arises from the illegal drug's unique characteristic that renders it indistinct, not readily identifiable, and easily open to tampering, alteration or substitution either by accident or otherwise. Thus, to remove any doubt or uncertainty on the identity and integrity of the seized drug, evidence must definitely show that the illegal drug presented in court is the same illegal drug actually recovered from the accused-appellant; otherwise, the prosecution for possession under Republic Act No. 9165 fails.[18]
	GR No. 185715 2011-01-19	PEOPLE v. ERLINDA CAPUNO Y TISON BRION, J.
We had the same rulings in People v. Gutierrez,[37] People v. Denoman,[38] People v. Partoza,[39] People v. Robles,[40] and People v. dela Cruz,[41] where we emphasized the importance of complying with the required procedures under Section 21 of R.A. No. 9165.
	GR No. 185378 2010-09-27	PEOPLE v. JENNEFER CARIN Y DONOGA CARPIO MORALES, J.
In a prosecution for illegal sale of a prohibited drug, the prosecution must prove the following elements: (1) the identity of the buyer and the seller, the object, and the consideration; and (2) the delivery of the thing sold and the payment therefor. All these require evidence that the sale transaction transpired, coupled with the presentation in court of the body or substance of the crime that establishes that a crime has actually been committed.[19] Failure to comply with Section 21, paragraph (1) of Article II of RA No. 9165 and its implementing rules results, in certain cases such as in the present one, in failure to establish the existence of the crime.[20]
	GR No. 187741 2010-08-08	PEOPLE v. PETER M. CAMPOMANES MENDOZA, J.
Although Section 21(1) of R.A. No. 9165 mandates that the apprehending team must immediately conduct a physical inventory of the seized items and photograph them, non-compliance with said section 21 is not fatal as long as there is a justifiable ground therefor, and as long as the integrity and the evidentiary value of the confiscated/seized items are properly preserved by the apprehending team.[27] Thus, the prosecution must demonstrate that the integrity and evidentiary value of the evidence seized have been preserved.[28]
	GR No. 178202 2010-05-14	PEOPLE v. NORMAN SITCO VELASCO JR., J.
Although the non-presentation of some of the witnesses who can attest to an unbroken chain of custody of evidence may, in some instances, be excused, there should be a justifying factor for the prosecution to dispense with their testimonies.[27] In People v. Denoman,[28] the Court discussed the saving mechanism provided by Sec. 21(a), Article II of the Implementing Rules and Regulations of RA 9165.[29] Denoman explains that the aforementioned provision contains a saving mechanism to ensure that not every case of non-compliance will permanently prejudice the prosecution's case. The saving mechanism applies when the prosecution recognizes and explains the lapse or lapses in the prescribed procedures.[30] In this case, the prosecution did not even acknowledge and discuss the reasons for the missing links in the chain.
	GR No. 174198 2010-01-19	PEOPLE v. ZAIDA KAMAD Y AMBING BRION, J.
We applied this ruling in People v. Garcia,[27] People v. Gum-Oyen,[28] People v. Denoman[29] and People v. Coreche[30] where we recognized the following links that must be established in the chain of custody in a buy-bust situation: first, the seizure and marking, if practicable, of the illegal drug recovered from the accused by the apprehending officer; second, the turnover of the illegal drug seized by the apprehending officer to the investigating officer; third, the turnover by the investigating officer of the illegal drug to the forensic chemist for laboratory examination; and fourth, the turnover and submission of the marked illegal drug seized from the forensic chemist to the court.

PEOPLE v. EDGAR DENOMAN Y ACURDA