G.R. No. L-2933 - Everett Steamship Corp. vs. Chuahiong

The case arises from an Information filed at the Regional Trial Court (RTC) of Batangas City, Branch 84, charging petitioner Riel Aranas y Dimaala with Illegal Possession of Dangerous Drugs under Section 11, Article II of Republic Act (RA) 9165, otherwise known as the "Comprehensive Dangerous Drugs Act of 2002."
The alleged offense occurred on May 13, 2015, when police, under a valid search warrant issued on May 7, 2015, conducted a search at petitioner’s residence in Barangay Sto. Tomas, Tingloy, Batangas.

At approximately 6:00 in the morning on May 13, 2015, members of the Tingloy Police Station executed Search Warrant No. 15-20 at petitioner’s residence.
Police Officers PO1 Benjie Casapao and PO1 Rolando Togonon read the warrant aloud, then proceeded to search the premises where they discovered:

Two plastic sachets suspected to contain shabu found inside a Katialis ointment container.
Additional items including a rolled aluminum foil and a lighter mounted on the wall.

After the search, petitioner was arrested in the presence of Barangay Chairman Aileen Mendoza, media representative Benedicto GriAo, and Department of Justice (DOJ) representative Judith Buhay.
The seized items were immediately marked, inventoried, and photographed at the scene to establish their condition and identity.

The marked items were delivered to the Batangas Provincial Crime Laboratory Office by PO1 Togonon, where laboratory tests confirmed the presence of methamphetamine hydrochloride (shabu).
The chain of custody was maintained as the items were handed over subsequently to Police Senior Inspector Herminia Carandang Llacuna, then to Evidence Custodian Joel Barcelona for safekeeping.
Mandatory procedures were followed, including the immediate marking, inventory, and photography conducted in the presence of required witnesses (an elected public official, a media representative, and a DOJ representative).

Petitioner claimed that the police officers had conducted an unauthorized and sudden entry into his residence at around 3:00 in the morning, asserting that the drugs had been found on the second floor after a forced search.
In his defense, petitioner denied possessing illegal drugs; however, his testimony was found less credible compared to the evidence adduced by the prosecution.
On July 14, 2017, the RTC rendered a Judgment finding petitioner guilty beyond reasonable doubt, sentencing him to an indeterminate imprisonment period (minimum of 12 years and 1 day; maximum of 13 years and 1 day) and imposing a fine of P300,000.00.

Petitioner appealed the RTC’s decision to the Court of Appeals (CA), which, on June 29, 2018, affirmed the conviction.
The CA emphasized that the prosecution demonstrated with moral certainty all necessary elements of the crime and maintained an unbroken chain of custody over the seized drugs.
A subsequent motion for reconsideration was filed by petitioner, but the CA denied it via a Resolution dated September 18, 2018, which led to the current petition for review on certiorari.

Whether the prosecution was able to establish with moral certainty the three essential elements of Illegal Possession of Dangerous Drugs:

Whether the chain of custody of the seized evidence was properly preserved from the time of seizure until its presentation in court.
Whether the minor inconsistencies in the testimonies of prosecution witnesses have any bearing on the credibility and sufficiency of the evidence.
Whether petitioner’s assertion alleging an unauthorized search and subsequent irregularities can negate the established evidentiary procedures and findings of the trial court.