Case Digest (G.R. No. 256233)
Facts:
People of the Philippines v. Nixon Cabanilla y Crisologo, Michael Cabardo y Cordevilla, and Gomer Valmeo y Comilang, G.R. No. 256233, August 09, 2023, Supreme Court Second Division, Lopez, J., writing for the Court.The case arose from events on January 29, 2017, in Barangay West Crame, San Juan City, where Police Officer (PO) 3 Rennel Espano (PO3 Rennel), PO2 Ryan Fuentes (PO2 Ryan), and Police Inspector John Jefferson delos Reyes (PInsp. John) encountered a parked jeepney with three men inside. The officers testified they saw one occupant (later identified as Nixon) half‑naked, and PInsp. John instructed the officers to verify his identity under a local ordinance prohibiting public toplessness. PO3 Rennel approached, boarded the jeepney, observed alleged drug paraphernalia on the floor, seized items (two plastic sachets, foil, improvised tooter, lighters, scissors) and arrested Nixon, Michael, and Gomer. The seized items were photographed, marked, and inventoried at the police precinct in the presence of a barangay kagawad and a Department of Justice (DOJ) representative; a later chemistry report by PCI Margarita Libres confirmed Methamphetamine Hydrochloride.
The accused pleaded not guilty and denied the shirtless appearance of Nixon, claiming they were merely together and were approached by police. The Regional Trial Court (RTC), Pasig City, Branch 68, convicted the three for violation of Section 13 of Republic Act No. 9165 (possession during social gatherings) and subsumed Section 14 (paraphernalia), imposing life imprisonment and fines, and ordered destruction of the seized items through PDEA. The Court of Appeals (CA), Second Division, affirmed the RTC’s February 22, 2019 joint judgment in a June 2, 2020 decision, finding the officers’ testimonies credible, upholding the in flagrante delicto arrest and chain of custody.
The accused sought review in the Supreme Court assailing the CA decision, contending inter alia that the warrantless arrest and search were invalid for failur...(Subscriber-Only)
Issues:
- Was the warrantless arrest and the attendant search incidental to that arrest lawful under Rule 113, Section 5 and Rule 126, Section 13 of the Rules of Court and the Constitution?
- Did the prosecution satisfactorily preserve and prove the chain of custody of the seized items under Section 21 of Republic Act No. 9165, as amended by RA 10640?
- Did the accused violate Section 13 of Republic Act...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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