Facts:

This case involves Margarita Ambre y Cayuni (Petitioner) and the People of the Philippines (Respondent), with the decision dated August 15, 2012, by the Supreme Court. The events leading to this case unfolded on April 20, 2005, in Caloocan City, when a buy-bust operation was conducted by the Caloocan Police Anti-Illegal Drug-Special Operation Unit. Based on a tip-off, the police were investigating Abdulah Sultan and his wife, Ina Aderp, suspected of selling dangerous drugs from a residential compound. During the operation, while chasing Sultan, officers found Ambre, along with co-accused Bernie Castro and Kaycee Mendoza, engaged in inhaling methylamphetamine hydrochloride (shabu). They were arrested, and items such as sachets with traces of shabu and aluminum foil were recovered.

Two separate Informations were filed against Ambre and her co-accused: Criminal Case No. C-73028 for illegal possession of drug paraphernalia and Criminal Case No. C-73029 for illegal use of shabu. Cas

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Facts:

Parties and Criminal Charges

• Separate Informations were filed against Margarita Ambre y Cayuni (petitioner) and her co-accused, Bernie Castro and Kaycee Mendoza, before the Regional Trial Court (RTC).
• The charges included:
• In Criminal Case No. C-73028 – illegal possession of drug paraphernalia, specifically unsealed sachets, rolled and folded aluminum foil strips containing traces of methylamphetamine hydrochloride, and disposable lighters.
• In Criminal Case No. C-73029 – illegal use of methylamphetamine hydrochloride (shabu).

Arraignment and Plea

• At arraignment, Castro and Mendoza pleaded guilty to the charges; they were sentenced to imprisonment and rehabilitation.
• Ambre, on the other hand, pleaded not guilty, prompting a trial on the merits.

Prosecution’s Version and Buy-Bust Operation

• The buy-bust operation occurred on April 20, 2005, following a tip-off regarding drug selling activity at a Caloocan City residential compound.
• Key facts as testified by prosecution witnesses (PO3 Moran, PO1 Mateo, PO2 Hipolito, and P/Insp. dela Rosa):
• Police operatives, during the operation, arrested individuals including Aderp and Tagoranao after an attempted pursuit of a suspect, Sultan, who then led officers to his residence.
• At Sultan’s house, Ambre, along with Castro and Mendoza, was discovered allegedly engaged in a “pot session” where Ambre was seen sniffing suspected shabu from an aluminum foil.
• Confiscated items were later subjected to laboratory examination, with physical science reports confirming the presence of shabu in the drug paraphernalia and positive urine samples from the accused.

Defense’s Version and Testimonies

• Ambre and her defense witnesses (including co-accused Mendoza and Lily Rosete) contended that:
• Ambre was at the residential compound for a routine purchase (malong) and was unexpectedly left behind when Rosete went to look for vendors; she was later apprehended when police officers entered the compound.
• Ambre denied having engaged in any act involving drug consumption, asserting that no “pot session” took place.
• Testimonies varied, with Mendoza asserting that the events were more of a sudden police intrusion with guns pointed at them, and Rosete testifying about the timing and circumstances surrounding Ambre’s arrest.

Trial Court and Appellate Proceedings

• The RTC rendered a decision on September 1, 2008, finding Ambre guilty only of illegal use of shabu (violation of Section 15, Article II of R.A. No. 9165) while acquitting her of drug paraphernalia possession (Section 12, Article II) due to insufficient evidence.
• The Court of Appeals (CA) subsequently affirmed the RTC decision on November 26, 2009, and later denied Ambre’s motion for reconsideration on March 9, 2010.

Issue:

Validity of Arrest and Search Procedures

• Whether the warrantless arrest of Ambre and the subsequent search conducted during the buy-bust operation conformed to mandated legal procedures.
• Whether the entry into Sultan’s dwelling and the manner of apprehension of Ambre violated any defensive rights.

Legality and Admissibility of the Seized Evidence

• Whether the items seized from Ambre are inadmissible as fruits of a “poisonous tree” due to alleged irregularities in the arrest and search procedures.
• Determination if any failure to comply strictly with the prescribed chain of custody procedures undermined the evidentiary integrity of the drug paraphernalia.

Exclusion of Favorable Testimony

• Whether excluding the favorable testimony of co-accused Kaycee Mendoza—who had pleaded guilty—violated the rule on inter alios acta under Section 26, Rule 130 of the Rules of Court.

Sufficiency of the Imposed Penalty

• Whether imposing the penalty of six months of rehabilitation in a government center, in light of the alleged absence of a confirmatory drug test as required under R.A. No. 9165, constitutes a nullity.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)