Case Digest (G.R. No. 199938)
Facts:
People of the Philippines v. Camaloding Laba y Samanoding, G.R. No. 199938, January 28, 2013, Supreme Court Second Division, Perlas-Bernabe, J., writing for the Court. Appellant Camaloding Laba y Samanoding (appellant) was arrested at the Manila Domestic Airport in Pasay City on July 18, 2005, shortly before his flight to Davao City. While at the initial check‑in area a non‑uniformed frisker, Mark Anthony Villocillo, physically searched appellant and felt an object in appellant’s oversized white rubber shoes marked “Spicer.” Villocillo asked appellant to remove the shoes and discovered three plastic sachets—two in the left shoe and one in the right—containing a white crystalline substance; upon extraction appellant said, “Baka pwedeng pag‑usapan ito,” and handed Villocillo a rolled wad of bills. Villocillo called his supervisor, SPO2 Nolasco Peji, who apprehended appellant, apprised him of his rights, and brought him to an office where PO2 Edwin Caimoso investigated; PDEA agents later took custody of appellant and the seized items.The PDEA, through Police Inspector Peter P. Alvarez, requested laboratory examination of the three seized sachets, which were marked and weighed as three exhibits totaling 196.63 grams. The following day (as reported in the records), forensic chemist Police Senior Inspector Stella Garciano Ebuen conducted a qualitative examination and tested the substance positive for methylamphetamine hydrochloride (shabu). An Information was filed charging appellant with violation of Section 5, Article II of Republic Act No. 9165 (transportation of dangerous drugs). Appellant pleaded not guilty at arraignment and during trial denied ownership of the shoes and the drugs, claimed he had been framed, and asserted that officers attempted to extort a P100,000 settlement; he also alleged that officers confiscated money from his person.
The Regional Trial Court (RTC), Branch 231, Pasay City, after trial convicted appellant on August 29, 2006, finding the prosecution witnesses credible, that corpus delicti and actual possession were established, and sentenced appellant to life imprisonment and a P500,000 fine. The Court of Appeals (CA), in CA‑G.R. CR‑HC No. 02479, affirmed the RTC in toto on April 7, 2011, ruling that the identity of the seized substance and the chain ...(Subscriber-Only)
Issues:
- Did the RTC and the Court of Appeals commit reversible error in convicting appellant of transporting shabu under Section 5, Article II of RA 9165?
- Was the chain of custody for the seized drugs properly established so as to render the seized evidence admissible despite non‑strict compliance with Section 21, par. (1) of RA 9165?
- Does the non‑presentation in court of the forensic chemist who conducted the laboratory e...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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