G.R. No. 174369 - People vs. Maraorao y Macabalang

The appellant, Zafra Maraorao y Macabalang, was charged with illegal possession of dangerous drugs under Section 16, Article III of Republic Act No. 6425 (Dangerous Drugs Act of 1972, as amended).
The Information dated January 4, 2001, charged appellant with possessing one transparent plastic sachet containing 1,280.081 grams of a white crystalline substance (shabu containing methylamphetamine hydrochloride) without license or prescription.
Appellant pleaded not guilty on March 19, 2001.

Patrol Officer (PO3) Manuel Vigilla testified that on November 29, 2000, the police received reliable information about a shabu delivery inside the Islamic Center in Quiapo.
On November 30, 2000, around 7:00 a.m., PO3 Vigilla, PO2 Mamelito Abella, PO1 Joseph dela Cruz, and SPO1 Norman Gamit proceeded to the Islamic Center.
They saw two men conversing; upon noticing the police, one man fled while the other dropped a maroon Adidas bag.
PO3 Vigilla apprehended the man who dropped the bag, identified as the appellant, and SPO1 Gamit retrieved the bag.
The plastic sachet containing the suspected shabu was marked as Evidence (aZM-1a).
Forensic Chemist P/Insp. Miladenia O. Tapan analyzed the substance and confirmed it contained 1,280.081 grams of methylamphetamine hydrochloride (Chemistry Report No. D-1121-00).

Appellant testified that he was going to his uncle’s place in the Islamic Center to get a letter from his mother at around 7:00 a.m. on November 30, 2000.
On the way, an unidentified man carrying a bag asked him about a house number, which he did not know.
While talking to the man, they noticed four men in civilian clothes (police officers) who pursued the man carrying the bag.
The man fled, dropping the bag; appellant was arrested despite his denial of ownership of the bag.
Appellant claimed he was not assisted by counsel during the investigation and was confined for about ten days before jail transfer.

The RTC convicted appellant of illegal drug possession, sentencing him to reclusion perpetua and a fine of PHP 5 million.
The Court of Appeals affirmed the RTC decision, giving full credence to PO3 Vigilla’s testimony and rejecting appellant’s defense.
The appellate court held that the warrantless arrest and search were lawful.

Appellant appealed before the Supreme Court, arguing the arrest was illegal due to lack of probable cause and that the subsequent search and seizure were invalid.
Appellant also pointed out discrepancies in PO3 Vigilla’s testimony regarding who actually dropped the bag and who was apprehended.

Whether the prosecution proved beyond reasonable doubt that appellant was in possession of the illegal drug.
Whether the warrantless arrest of appellant was lawful and supported by probable cause.
Whether the search and seizure of the bag containing shabu were valid and admissible as evidence.
Whether the trial court and Court of Appeals erred in giving full credence to the prosecution’s witnesses and disregarding appellant’s defense.