Case Digest (G.R. No. 242017)
Facts:
People of the Philippines v. JR S. Macarona and Meloy M. Macarona, G.R. No. 242017, October 06, 2021, Supreme Court Third Division, Leonen, J., writing for the Court. The case is a criminal prosecution for illegal transportation of dangerous drugs under Republic Act No. 9165.The prosecution (the People of the Philippines) charged accused-appellants JR S. Macarona and Meloy M. Macarona with transporting 92.2303 grams of methamphetamine hydrochloride (shabu) on or about January 2, 2015 in Lupon, Davao Oriental. The Information alleged they sold, transported and possessed shabu without authority. Upon arraignment the Macaronas pleaded not guilty and the case proceeded to trial before the Regional Trial Court (RTC), Branch 32, Lupon.
Prosecution evidence: a confidential informant allegedly tipped Police Officer 2 Leo Michael T. Sapalicio that a white Mitsubishi L300 van was transporting illegal drugs from Davao City to Lupon. A checkpoint was set up, the van was stopped, and Police Officer 1 Elizalde Ronquillo observed a sachet containing white crystalline substance in the driver’s visor. In the presence of barangay officials the van was searched and four sachets were seized, marked, turned over for laboratory examination and later tested positive for 92.2303 grams of shabu by Police Inspector Jade Ryan Bajade; custody thereafter passed to Police Officer 3 Ermer Cubillan who kept the exhibits until trial.
The Macaronas denied knowledge of the drugs, asserted that no inventory or marking was done at the checkpoint, and said the marking occurred only later at the police station. At trial the prosecution presented five witnesses (custodian, forensic chemist, duty investigator, barangay captain, and an apprehending officer). The RTC convicted the Macaronas beyond reasonable doubt, found the warrantless search valid, and held the chain of custody intact; it sentenced them to life imprisonment and fines, and forfeited the seized sachets to the government.
The Macaronas appealed to the Court of Appeals (CA). The CA affirmed the RTC judgment, sustaining the validity of the warrantless search and the chain of custody. The Macaronas s...(Subscriber-Only)
Issues:
- Was the warrantless search and seizure of the white L300 van and the seized sachets lawful under the Constitution and established jurisprudence?
- Did the prosecution sufficiently establish the chain of custody and the identity/integrity of the seized drugs under Section 21 of Republic Act No. 9165 and its Implementing Rules?
- Did the prosecution prove the guilt of the accused beyond reasonable doubt for ille...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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