even in a warrantless seizure, the general rule that the inventory and taking of photographs must be conducted at the place of seizure remains. In People v. Musor48 (Musor) it was declared by the Court that the phrase "immediately after seizure and confiscation" means that the physical inventory and photographing of the drugs were intended by the law to be made immediately after, or at the place of apprehension.
Accordingly, as current jurisprudence stand, in case of warrantless seizures, the inventory and taking of photographs generally must be conducted at the place of seizure. The exception to this rule is when the police officers provide justification that: 1. It is not practicable to conduct the same at the place of seizure; or 2. The items seized are threatened by immediate or extreme danger at the place of seizure.
Accordingly, before the prosecution can invoke the saving clause, they must satisfy the two requisites: 1. The existence of "justifiable grounds" allowing departure from the rule on strict compliance; and 2. The integrity and the evidentiary value of the seized items are properly preserved by the apprehending team.
Similary, the Court, in People v. Lim50 (Lim), reiterated the general rule that the inventory and taking of photographs in case of warrantless seizure must be conducted at the place of seizure unless there is a threat of immediate or extreme danger; in which case, the inventory and taking of photographs can be conducted at the nearest police station, to wit: We have held that the immediate physical inventory and photograph of the confiscated items at the place of arrest may be excused in instances when the safety and security of the apprehending officers and the witnesses required by law or of the items seized are threatened by immediate or extreme danger such as retaliatory action of those who have the resources and capability to mount a counter-assault.51 (emphasis supplied)
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