G.R. No. 230964 - CICL XXXvs. People

Petitioners: CICL XXX, CICL YYY (minors), Jonathan Solina y Solina alias “Jun-Jun,” and Jed Barba y Apolonio alias “Jed.”
Respondent: People of the Philippines.
Lower courts: RTC Branch 254 convicted petitioners in Crim. Cases 06-0260 (illegal possession of marijuana) and 06-0261 (illegal possession of paraphernalia); CA affirmed.

On March 8, 2006 at about 12:30 a.m., PO2 Wilson Paule, P/Supt. Alberto Romero, P/Insp. Mario Solero, PO2 Rufino Dalagdagan, and P/Insp. Fergen Torred conducted a warrantless anti-criminality operation at a known drug hub (“Shabu Hotel”).
Through a slightly open door, they saw four individuals (XXX, YYY, Jed, Jonathan) seated around two transparent sachets of suspected marijuana and an improvised glass pipe.
PO2 Paule and PO2 Dalagdagan entered, introduced themselves, confiscated the sachets and pipe, arrested the suspects, read them their rights, and brought them to the Drugs Enforcement Unit (DEU).
At the station, PO2 Michael Holanda marked the seized items in the presence of the accused, prepared the investigation report and request for lab exam, and turned over the items to the PNP crime lab in Makati.
Forensic chemist PI Richard Allan Mangalip tested the specimens positive for marijuana. Affidavits of arrest and testimonies corroborated marking and chain of custody.

On the same night around 11:00 p.m., petitioners claimed they were en route to borrow a CD from Jed and were joined by Jonathan.
Upon arrival, PO2 Paule allegedly instructed them into Jed’s room, showed them a sachet of marijuana without conducting an inventory or taking photos, then escorted them to a nearby basketball court with other arrestees and video-recorded them.
They were taken to the DEU, then to Makati for drug tests (results not disclosed), and returned to the station for detention.

Two Informations filed: Crim. 06-0260 for possession of 2.50 g marijuana; Crim. 06-0261 for possession of a glass pipe. Petitioners pleaded not guilty; minority of XXX and YYY was duly stipulated.
Joint trial ensued. RTC’s Joint Decision (Dec. 20, 2012) found all guilty, imposed prison terms and fines, applied minority mitigation for YYY.
CA Decision (Dec. 14, 2016) affirmed RTC, reduced fine in Case 06-0261 to ₱10,000; CA Resolution (Apr. 3, 2017) denied reconsideration.
Petitioners filed a petition for review on certiorari before the Supreme Court.

Whether the trial court and CA erred in not exempting YYY (17 years old) from liability as a minor offender.

Whether the CA gravely erred in relying on the testimonies of PO2 Paule and PO2 Dalagdagan as credible.

Whether the seized marijuana and pipe are inadmissible as fruits of an illegal arrest and warrantless search (poisonous tree doctrine).

Whether the CA erred in upholding conviction despite the prosecution’s failure to establish the identity and integrity of the confiscated items through unbroken chain of custody.