G.R. No. 242017 - People vs. Macarona

JR S. Macarona and Meloy M. Macarona (the Macaronas) were charged with illegal transportation of Methamphetamine Hydrochloride (“shabu”) in the Municipality of Lupon, Davao Oriental.
The Information alleged that on or about January 2, 2015, the Macaronas, without authority of law, willfully and unlawfully transported 92.2303 grams of shabu in a white Mitsubishi L300 van.

At around 2:00 p.m. on January 2, 2015, a confidential informant informed Police Officer 2 Leo Michael T. Sapalicio that the accused were transporting illegal drugs from Davao City to Lupon.
Based on this tip, a checkpoint was established in Purok Macopa within the hour.
At 4:00 p.m., Police Officer 1 Elizalde Ronquillo flagged down the mentioned vehicle. Upon rolling down the windows, a sachet with white crystalline substance was seen at the driver’s visor.
A search was conducted in the presence of barangay officials, resulting in the seizure of a total of four sachets containing white crystalline substance found in various parts of the vehicle.

The seized items were marked on the spot and later turned over for laboratory examination.
Police Inspector Jade Ryan Bajade, the forensic chemist, positively identified the contents as 92.2303 grams of shabu.
Police Officer 3 Ermer Cubillan served as evidence custodian, maintaining the items until court presentation.

The Macaronas denied knowledge or possession of the seized drugs.
Meloy testified he was hired as the driver to bring the van from Davao City to Mati City, with JR as a mere companion.
They contended that the police did not mark or inventory the seized items at the checkpoint, and the police only performed inventory and marking at the police station without their presence.
The Macaronas also argued the warrantless search was unlawful, being based solely on a confidential informant’s tip without probable cause.

The Regional Trial Court (RTC) found the Macaronas guilty beyond reasonable doubt of violating Section 5 of Republic Act No. 9165. It held the warrantless search valid due to probable cause and ruled the chain of custody for the drugs was intact.
The Court of Appeals (CA) affirmed the RTC’s decision and resolution, maintaining the validity of the warrantless search and proper preservation of the corpus delicti.
The Macaronas filed a motion for reconsideration, which was denied by the CA.
Subsequently, they elevated the case to the Supreme Court.

Whether the warrantless search and seizure conducted by the police were valid despite being based on a confidential informant’s tip.
Whether the probable cause requirement was met to justify the warrantless search of the vehicle.
Whether the seized items (shabu) were properly marked, inventoried, and preserved authorizing their admissibility in evidence.
Whether the chain of custody of the seized drugs was strictly observed pursuant to Section 21 of Republic Act No. 9165 and its Implementing Rules and Regulations.