Facts:

The case involves the appellant, Siegfredo Obias, Jr. y Arroyo, also known as "Boboy," who was found guilty of violating Sections 11 and 12 of Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002. The events leading to the case began on September 11, 2008, when the National Bureau of Investigation (NBI) secured two search warrants from Executive Judge Jaime E. Contreras to search Obias's rest house and cock farm located at Diamond Street, Villa Grande Homes Subdivision, Concepcion Grande, Naga City. The search warrants were issued based on surveillance and test buy operations indicating that Obias was dealing with shabu, a prohibited drug. On September 13, 2008, NBI agents, assisted by the Philippine National Police (PNP) and the Philippine Drug Enforcement Agency (PDEA), executed the search warrants. They invited local officials, media representatives, and prosecutors to witness the search. During the search, various drug paraphernalia and sever...

Facts:

Surveillance and Test Buy Operations:
The National Bureau of Investigation (NBI) Legaspi District Office conducted surveillance and test buy operations on Siegfredo Obias, Jr. (accused-appellant) for allegedly dealing with shabu at his rest house and cock farm in Naga City.

Issuance of Search Warrants:
On September 11, 2008, Executive Judge Jaime E. Contreras issued Search Warrant Nos. 2008-021 and 2008-022 authorizing the search of Obias’ premises for shabu and drug paraphernalia.

Implementation of Search Warrants:
On September 13, 2008, NBI agents, assisted by the Philippine National Police (PNP) and the Philippine Drug Enforcement Agency (PDEA), executed the search warrants. Barangay Chairman Elmer Baldemoro, media representatives, and Assistant City Prosecutors were present.

Recovery of Evidence:
During the search, the team found several plastic sachets of white crystalline substance (later confirmed as shabu) and drug paraphernalia in various locations within the premises, including the bedroom, kitchen, and under the house. The items were marked, inventoried, and photographed in the presence of witnesses.

Chemical Examination:
The seized items were examined by Forensic Chemist P/Insp. Edsel Villalobos, who confirmed the presence of methamphetamine hydrochloride.

Charges Filed:
Obias was charged with illegal possession of dangerous drugs (Section 11, RA 9165) and illegal possession of drug paraphernalia (Section 12, RA 9165).

Defense’s Claim:
Obias denied the charges, alleging that the seized items belonged to his employees and that he was not present during the search of certain areas.

Issue:

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Ruling:

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Ratio:

1. Lawfulness of Search and Seizure:
   The search warrants were validly issued, and the implementation complied with the constitutional requirement of reasonableness. The presence of barangay officials, media representatives, and prosecutors ensured the integrity of the process.

2. Constructive Possession:
   As the owner of the premises, Obias had control and dominion over the areas where the illegal items were found, constituting constructive possession under the law.

3. Chain of Custody:
   The prosecution adequately proved the chain of custody of the seized items, ensuring the integrity and evidentiary value of the drugs and paraphernalia.

4. Minor Inconsistencies:
   Minor discrepancies in the testimonies of witnesses do not undermine the credibility of the evidence, especially when they pertain to collateral details and do not affect the core elements of the crime.

5. Application of Penalties:
   The penalties imposed were consistent with the provisions of RA 9165 and the Indeterminate Sentence Law, ensuring proportionality and compliance with legal standards.