Title
Supreme Court
People vs. Chi Chan Liu
Case
G.R. No. 189272
Decision Date
Jan 21, 2015
Two Chinese nationals aboard a speedboat near Ambil Island, Occidental Mindoro, were apprehended with suspected shabu in 1998. Despite bribery attempts, illegal possession was proven, not importation, leading to life sentences.

Case Digest (G.R. No. 189272)
Expanded Legal Reasoning Model

Facts:

  • Incident and Arrest
    • On December 3, 1998, SPO2 Paglicawan and SPO3 Yuzon of PNP Looc received a tip about a suspicious boat near Ambil Island.
    • They observed two boats side by side—a fishing boat and a speedboat—transferring cargo; the fishing boat fled.
    • Boarding the speedboat, officers found appellants Chi Chan Liu (aka Chan Que) and Hui Lao Chung (aka Leofe Senglao) with 45 transparent bags containing a white crystalline substance (approx. 46.6 kg).
  • Custodial Proceedings
    • Appellants failed to show identification, offered bribes en route to shore, and were towed to Looc police station.
    • In the presence of Mayor Telebrico, the 45 bags were inventoried; appellants remained uncooperative, repeating “call China, big money.”
    • An interpreter arrived on December 5; appellants were informed of rights but made no substantive statements beyond their names and alias.
  • Laboratory Examination and Information
    • PNP Chief Forensic Chemist Geronimo conducted tests and confirmed the substance as methamphetamine hydrochloride (shabu).
    • On December 8, 1998, the Provincial Prosecutor filed an Information charging appellants with illegal importation of regulated drugs (45 bags, 46.6 kg) under RA 6425 as amended by RA 7659.
    • Appellants pleaded not guilty; trial featured prosecution witnesses (officers, chemist) and defense witnesses claiming the drugs were planted.
  • Trial and Lower Decisions
    • RTC Branch 44, Mamburao (June 21, 2004) found appellants guilty beyond reasonable doubt of importation/conspiracy under Sec. 14, Art. III and Sec. 21(a), Art. IV, RA 6425; sentenced each to reclusion perpetua and P1,000,000 fine.
    • CA (January 9, 2009) affirmed the RTC decision; denied reconsideration (April 24, 2009).
    • SC appeal raised five issues: elements of importation, corpus delicti, presumption of regularity vs. constitutional rights, validity of arraignment, and sufficiency of proof.

Issues:

  • Whether the elements of illegal importation of regulated drugs (Sec. 14, Art. III, in relation to Sec. 21(a), Art. IV, RA 6425 as amended) are present.
  • Whether the corpus delicti of the crime charged was established beyond reasonable doubt.
  • Whether the presumption of regularity in official duties prevails over appellants’ constitutional guarantees in this case.
  • Whether appellants’ arraignment was valid.
  • Whether appellants’ guilt was proven beyond reasonable doubt.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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