Case Digest (G.R. No. 101251)
Facts:
The case involves respondents Nixon Cabanilla y Crisologo, Michael Cabardo y Cordevilla, and Gomer Valmeo y Comilang, who were charged under Criminal Case Nos. 21423-D-SJ and 21424-D-SJ relating to possession of dangerous drugs pursuant to Section 13, Article II of Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002, as amended. The incident occurred on January 29, 2017, in Barangay West Crame, San Juan City. Police Officer (PO) 3 Rennel EspaAo (PO3 Rennel), PO 2 Ryan Fuentes, and Police Inspector John Jefferson delos Reyes were on patrol when they spotted the accused inside a parked jeepney, one of whom, Nixon, was allegedly half-naked violating a San Juan City ordinance against public toplessness. The police approached and questioned Nixon and discovered drug paraphernalia scattered inside the vehicle. Subsequently, the police arrested the accused and seized various drug-related paraphernalia and a small quantity of methamphetamine hydrochloride (shabu). The s...
Case Digest (G.R. No. 101251)
Facts:
- Charges and Arrest
- Nixon Cabanilla, Michael Cabardo, and Gomer Valmeo (the accused) were charged under the Comprehensive Dangerous Drugs Act of 2002 (RA 9165) for possession of dangerous drugs and drug paraphernalia on January 29, 2017, in San Juan City.
- The accused allegedly possessed heat-sealed plastic sachets containing methamphetamine hydrochloride (shabu) and drug paraphernalia during a pot session inside a parked jeepney.
- Police Officers Rennel EspaAo (PO3 Rennel), Ryan Fuentes (PO2 Ryan), and Inspector John Jefferson delos Reyes were patrolling when they saw Nixon half-naked inside the jeepney, a violation of a local ordinance prohibiting toplessness in public.
- The police approached, questioned the accused, and upon PO3 Rennel boarding the jeepney, discovered drug paraphernalia on the floor; the accused were arrested in flagrante delicto.
- Handling of Evidence
- The seized items were inventoried and photographed at the police precinct in the presence of the accused, a barangay kagawad, and a DOJ representative.
- The chain of custody forms showed one sachet was already opened upon seizure.
- The items were submitted to the Eastern Police District Crime Laboratory, where they tested positive for methamphetamine hydrochloride.
- Trial Court and Appeals
- The RTC convicted the accused, finding their arrest valid under an in flagrante delicto theory due to violation of the ordinance and possession of drugs.
- The Court of Appeals affirmed the conviction, upholding the officers' credibility, legality of arrest, and chain of custody.
- Defense and Issues Raised
- The accused denied being half-naked and claimed they were resting; the arrest was based on doubtful testimonies and improper chain of custody.
- They appealed to the Supreme Court, contesting the validity of the warrantless arrest, search, and adherence to the chain of custody rule.
Issues:
- Whether the accused were validly arrested in flagrante delicto and whether the warrantless search was lawful and the seized evidence admissible under the chain of custody rule.
- Whether the prosecution established guilt beyond reasonable doubt for violation of Section 13 of RA 9165.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)