G.R. No. 138929 - People vs. Del Mundo

The case arises from a direct appeal challenging the decision of the Regional Trial Court of Balayan, Batangas, Branch 10.
Accused-appellant Florentino del Mundo was charged with violating Section 4, Article II of Republic Act No. 6425 (the Dangerous Drugs Act, as amended).

Date and Time: November 20, 1997, at approximately 4:30 p.m.
Location: Barangay Real, Municipality of Calatagan, Batangas.
Circumstances: A police team, acting on a reliable tip and following an order of battle against drug dealers, observed del Mundo standing by his tricycle and seen allegedly handing over an object.

The police observed del Mundo hastily board his tricycle and attempt to flee when officers approached.
Two policemen (PO2 Ramon Ancheta and PO1 Romeo Jonson) pursued him on a motorcycle, whereas two others (PO2 Leonardo Creus and PO2 Arnulfo Umali) chased the unidentified companion on foot.
During the search of del Mundo’s tricycle, officers located a plastic bag wrapped in newspaper containing a package that emitted the distinct scent of marijuana.

The package was opened, revealing two bricks of marijuana fruiting tops weighing a total of 1,720 grams.
The physical evidence was subjected to scientific analysis by P/Sr. Insp. Mary Jean Geronimo of the PNP Regional Crime Laboratory, which confirmed the substance as marijuana.

Prosecution witnesses included the arresting policemen and the forensic chemist, whose testimonies collectively established the chain of events and validated the physical and scientific evidence presented.
In contrast, the defense relied solely on the testimony of the accused, who provided an account that differed from the police version, asserting that an unidentified passenger was responsible for the bag and its contents.

The trial court found that the apprehending policemen’s actions and testimonies were credible, noting the uncontradicted evidence that the package was found in del Mundo's tricycle.
The hasty escape of del Mundo was regarded as an indication of consciousness of guilt, further bolstering the prosecution’s case.
The validity of the warrantless arrest and seizure was upheld on the grounds that the circumstances justified the actions under Rule 113, Section 5(a).

The trial court rendered a judgment convicting del Mundo for the violation of Section 4, Article II of R.A. 6425, sentencing him to reclusion perpetua and imposing a fine of P500,000.00.
The accused’s challenge on multiple legal errors (ownership issue, evidentiary sufficiency from the seizure location, the role of the unidentified passenger, validity of the warrantless procedures, and the overall conviction) formed the basis for the appeal.

Whether the trial court erred in holding that the ownership of the confiscated marijuana is not an issue in cases involving illegal drugs.

The appellant argued that proof of ownership was necessary for conviction.
The counter-argument emphasized that for malum prohibitum offenses such as those under R.A. 6425, ownership is immaterial.

Whether mere presence of the confiscated marijuana in the accused’s tricycle is sufficient in sustaining a conviction.

Appellant contended that being in the vicinity or having the substance in his vehicle does not necessarily establish guilt.
Prosecution relied on the presumptive evidence of possession and the contextual evidence of the accused’s actions (notably his attempt to flee).

Whether the unidentified passenger was in fact the owner and transporter of the marijuana.

The defense posited that the actual owner might have been the unidentified passenger who fled on foot.
The trial court, however, rejected this claim due to lack of credible corroborating evidence.

The validity of the warrantless arrest and subsequent seizure of the evidence.

Appellant challenged the warrantless nature of the search and arrest, asserting that his constitutional rights were violated.
The prosecution justified the warrantless procedures under the doctrine of immediate action in the field, given the circumstances of apprehension and the exigency of the situation.

Whether the prosecution has established beyond reasonable doubt that the accused was involved in selling, delivering, or transporting marijuana.

Del Mundo’s account was deemed uncorroborated and self-serving, failing to dispel the inferences drawn from the police testimony and physical evidence.