G.R. No. 271012 - Padillo vs. People

Roel Gementiza Padillo was charged with violating Section 11 of Republic Act No. 9165 for illegal possession of dangerous drugs, specifically methamphetamine hydrochloride ("shabu"), with a net weight of 51.7805 grams.
The charge stemmed from the discovery of 14 sachets containing shabu in his residence in Zone 3, Barangay Mantangale, Municipality of Balingoan, Misamis Oriental.
A search warrant (No. SW-208-2018) dated March 16, 2018, authorized the search of Padillo's residence.

On March 23, 2018, at about 10:00 p.m., the Philippine Drug Enforcement Agency (PDEA) Region 10 held a briefing to serve the search warrant against Padillo.
At around 1:20 a.m. on March 24, 2018, the PDEA team arrived at Padillo's residence. After announcing their authority and issuing calls, and with no response, they entered through an unlocked gate and used a battering ram to break into the house.
Inside, they found Padillo who was directed to vacate his room. Barangay officials and a media representative witnessed the proceedings.
The search yielded 14 sachets of white crystalline substances inside a plastic drawer in Padillo's room.
Padillo was informed of his rights, arrested, and handcuffed. Photographs were taken during the search, and items were inventoried and marked.
The seized drugs were delivered to Forensic Chemist Romelisa Ibale for laboratory examination, which confirmed the substance to be methamphetamine hydrochloride.

Padillo testified that the PDEA agents woke his family around 1:00 a.m., moved them to the living room, and read the search warrant. The search was conducted in various rooms including the master bedroom.
He denied ownership of the seized drugs and asserted that the agents asked if the drugs belonged to him while searching a drawer.
Several family members and a longtime household employee corroborated his account regarding the sequence of events during the search.

The Regional Trial Court (RTC) found the prosecution witnesses credible over Padillo’s denial, upheld the chain of custody, and found Padillo guilty beyond reasonable doubt.
The Court of Appeals (CA) affirmed the RTC decision, ruling that the prosecution proved the crime elements and the chain of custody was intact.
The CA held that the absence of the Evidence Custodian as a witness and the media and barangay officials' absence from the briefing did not affect the validity of the search warrant and operation.

Padillo argued that the search warrant service violated his constitutional rights due to the lack of his presence or two credible witnesses residing in the locality during the search, and procedural lapses in serving the warrant at night.
He also contended that the chain of custody was broken because the Evidence Custodian, who had possession for several months, was not presented as a witness.

Whether the search warrant issued and implemented against Padillo was valid.
Whether the prosecution properly established the integrity of the chain of custody of the seized drugs.
Whether Padillo's guilt for violating Section 11 of Republic Act No. 9165 was proven beyond reasonable doubt.