Case Digest (G.R. No. 192075)
Facts:
Roberto Palo y De Gula v. People of the Philippines, G.R. No. 192075, February 10, 2016, Supreme Court Third Division, Perez, J., writing for the Court. Petitioner Roberto Palo y De Gula (petitioner) was charged with violation of Section 11, Article II of R.A. No. 9165 (illegal possession of dangerous drugs) for alleged possession of 0.03 gram of methamphetamine hydrochloride (shabu) on July 24, 2002 in Valenzuela City.Petitioner and co-accused Jesus Daguman y Ramos were apprehended by police. After posting bail they were released; at the scheduled arraignment only Daguman appeared, while petitioner was initially absent due to an alleged mental disorder and was ordered for psychiatric evaluation. After being declared fit for trial petitioner was arraigned on March 10, 2003 and pleaded not guilty.
At trial the prosecution presented PO3 Miguel Capangyarihan who testified he saw petitioner holding a plastic sachet and recovered it from petitioner at close range, effecting a warrantless arrest in flagrante delicto. The parties stipulated to the testimony of other police officers and to chain-of-custody facts: the seized heat-sealed sachet marked “RPD” (Exhibit B) was turned over to investigators and ultimately submitted to the PNP Crime Laboratory where forensic chemical officer P/Insp. Juanita Sioson issued Chemistry Report No. D-706-02 confirming the sachet contained methylamphetamine hydrochloride weighing 0.03 gram. The defense presented petitioner and Daguman, who denied possession (petitioner claimed he was frisked and nothing found; Daguman said petitioner had the sachet and was arrested while Joseph, a third person, had other sachets).
The Regional Trial Court (RTC), Branch 171, Valenzuela City, convicted petitioner for illegal possession of dangerous drugs, finding he was caught in flagrante delicto and applying the presumption of regularity in police performance; Daguman was acquitted for insufficient evidence. The Court of Appeals (CA) in CA‑G.R. CR No. 31677 affirmed the RTC on September 22, 2009, holding the chain of custody intact and the arresting officer credible despite ...(Pro-only)
Issues:
- Was there sufficient evidence to convict petitioner beyond reasonable doubt for violation of Section 11, Article II of R.A. No. 9165?
- Did the arresting officers’ alleged non‑compliance with the chain of custody requirements under Section 21, Article II of R.A. No. 9165 and its IRR invalidate the evidentiary va...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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