Case Digest (G.R. No. 124442)
Facts:
In People of the Philippines v. Compacion (G.R. No. 124442, July 20, 2001), the respondent, Armando S. Compacion y Surposa, then Barangay Captain of Bagonbon, San Carlos City, Negros Occidental, was charged under Section 9, R.A. No. 6425, as amended by R.A. 7659, for planting and cultivating two full-grown Indian hemp (marijuana) plants in his backyard on July 13, 1995 at approximately 1:30 A.M. NARCOM agents, acting on a confidential tip and after surveillance on July 9, 1995, attempted to secure a search warrant on July 12 but were unable to obtain one—first for lack of jurisdiction, then due to office hours. Undeterred, they went to Compacion’s residence early on July 13, forced entry (the accused later denied consent), uprooted the two plants (Exh. “F”), performed a positive field test, and arrested him. On July 15, 1995, a forensic chemist at the PNP Crime Laboratory confirmed the specimens as marijuana through microscopic, chemical, and thin-layer chromatography tests. AtCase Digest (G.R. No. 124442)
Facts:
- Procedural History
- On July 13, 1995, Armando S. Compacion, barangay captain of Brgy. Bagonbon, San Carlos City, was charged under Section 9, RA 6425 (Dangerous Drugs Act), as amended, for planting two full-grown marijuana plants in his backyard.
- He pleaded not guilty on August 16, 1995. On January 2, 1996, the Regional Trial Court convicted him, sentencing him to reclusion perpetua, a ₱500,000 fine, and confiscation of the plants.
- Surveillance, Entry, and Seizure
- July 9, 1995: Based on a confidential tip, NARCOM officers surveilled the accused’s residence and observed two tall plants suspected to be marijuana.
- July 12–13, 1995: Attempts to secure a search warrant from two judges failed (lack of territorial jurisdiction and after-hours). Around 1:30 AM on July 13, officers forcibly entered without consent, questioned the accused, uprooted the plants, conducted an on-site field test (positive), and sent the specimens (Exh. “F”) to the PNP Crime Laboratory for confirmatory tests (microscopic, chemical, and TLC—all positive).
- Appellant’s Version and Appeal
- The accused denied consent, claimed unannounced armed men entered his home in the dark, searched for 20 minutes, and seized plants he said were medicinal.
- He challenged the admission of Exh. “F” for lack of chain of custody and contended that the warrantless search violated his constitutional rights, rendering the evidence “fruit of the poisonous tree.”
Issues:
- Whether the prosecution proved the identity and chain of custody of the seized plants as the corpus delicti planted by the accused.
- Whether the warrantless search and seizure violated the accused’s constitutional right against unreasonable searches and seizures, rendering the evidence inadmissible.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)