Facts:

• Lito Macabare was charged with illegal possession of 410.6 grams of methamphetamine hydrochloride (shabu).
• The incident took place on January 18, 2001, at the Manila City Jail, where Macabare had been detained since 1995 for a kidnapping charge.
• During a surprise inspection, jail officials found a plastic bag containing shabu inside a Coleman cooler in Macabare's kubol (cubicle).
• The prosecution presented testimonies from Senior Jail Officer II Arnel V. Sarino and Forensic Chemist Emilia Andeo-Rosales.
• Macabare denied ownership of the drugs, asserting that other inmates used his kubol.
• The Regional Trial Court (RTC) convicted him based on circumstantial evidence, sentencing him to reclusion perpetua and imposing a fine of P5 million.
• Macabare appealed to the Court of Appeals (CA), which upheld the RTC's ruling but reduced the fine to P500,000.

Issue:

• (Unlock)

Ruling:

• The Supreme Court affirmed Macabare's conviction, stating that the circumstantial evidence was sufficient to establish his guilt beyond reasonable doubt.
• The Court ruled that the presumption of innocence did no...(Unlock)

Ratio:

• A conviction based on circumstantial evidence requires an unbroken chain leading to the conclusion of guilt, excluding reasonable doubt.
• In Macabare's case, circumstantial evidence included his exclusive occupancy of the kubol, the discovery of the illegal substance in a cooler he controlled, and his failure to provide a credible explanation for its presence.
• The prosecution established a disputable presumption of own...continue reading