G.R. No. 219709 - Republic vs. Yeban

Antonio C. Estella was charged under Criminal Case No. RTC 2143-I with illegal possession of 8.320 kilograms of dried marijuana found in a hut in Purok Yakal, Barangay Baloganon, Masinloc, Zambales.
The Information alleged possession of multiple packages of dried marijuana and was read to appellant in Filipino, which he understood. He pleaded not guilty.
The Regional Trial Court (RTC) convicted Estella of violating Section 8, Article II of RA 6425 as amended by RA 7659, sentencing him to reclusion perpetua. He was acquitted of illegal possession of firearms in a separate charge.
Estella filed an appeal dated November 4, 1998.

A search warrant was issued by the Executive Judge for a search and seizure at appellant’s alleged residence.
On November 20, 1996, officers led by SPO1 Antonio Buloron, with assistance from local police and Barangay Captain Rey Barnachea, proceeded to and searched a hut in Purok Yakal.
Appellant was found sitting on a rocking chair about two meters away from the hut, allegedly owned by appellant’s brother Narding Estella and rented by appellant’s live-in partner Eva.
SPO1 Buloron claimed that appellant voluntarily surrendered two cans containing bricks of marijuana from inside the hut.
Police found additional marijuana and a .38 caliber revolver with ammunition inside the hut and seized these items.
The seized drugs underwent field testing and laboratory examination, confirming they were marijuana.
Appellant was arrested and brought to San Marcelino, Zambales.

Appellant denied ownership or occupancy of the hut that was searched; he claimed his real residence was a different house.
He denied having surrendered any marijuana or possession of firearms.
It was stated that the subject hut was owned by appellant’s brother and rented to spouses Vicente and Fely Bakdangan, with no proof that appellant controlled or used it for any purpose.
Witness Miguel Buccat claimed personal knowledge of appellant’s ownership of a different house.
During the search, appellant was outside the hut and did not accompany the police inside, contrary to the prosecution’s claim of voluntary surrender.

The RTC credited SPO1 Buloron’s testimony, finding it credible and consistent, and relied partly on Barangay Captain Barnachea’s presence to presume appellant’s ownership of the hut.
Probative value was granted to the police account, and appellant was convicted of illegal possession of dangerous drugs but acquitted for illegal possession of firearms due to lack of coverage by the search warrant.

Whether the search and seizure of marijuana in the hut were conducted lawfully and in adherence to appellant’s constitutional rights against unreasonable searches and seizures.
Whether appellant had ownership, control, or occupancy of the hut searched so as to be held liable for possession of the illegal drugs found therein.
Whether the evidence presented sufficiently proved appellant’s guilt beyond reasonable doubt.
Whether the trial court erred in finding appellant guilty despite contradictions and insufficiency of evidence presented by the prosecution.