Facts:

On March 29, 2005, at approximately 6:00 PM, a confidential informant notified SPO3 Melchor dela PeAa of the San Pedro Municipal Police Station about a pot session happening at the house of a certain person known as "Obeta" in Barangay Cuyab, San Pedro, Laguna. In response to the report, SPO3 Dela PeAa organized a police team consisting of the informant and several officers, including PO2 Rommel Bautista, PO3 Jay Parunggao, and PO1 Jifford Signap. By around 9:00 PM, the team arrived at the location; however, they found the house locked. PO2 Bautista, seeing a small opening, peeped inside and confirmed that a pot session was underway with four individuals present in a circle. Following this observation, PO3 Parunggao found an unlocked door, allowing the team to enter the house and surprise the suspects. Upon announcing their identities as police officers, they proceeded to arrest the four individuals and confiscated drug paraphernalia they found. Within this group were

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Facts:

Incident and Arrest

• On 29 March 2005, at around 6:00 p.m., a confidential informant notified SPO3 Melchor dela PeAa of a pot session taking place at a residence in Barangay Cuyab, San Pedro, Laguna.
• SPO3 Dela PeAa formed a police team composed of the confidential informant, PO2 Rommel Bautista, PO3 Jay Parunggao, and PO1 Jifford Signap to conduct an operation based on the received report.

Execution of the Operation

• At approximately 9:00 p.m. on the same day, the police team proceeded to the target area.
• Upon arrival, the team observed that the house was closed and unsupervised by a fence. PO2 Bautista peeped through a window and saw four individuals engaged in a pot session in the living room.
• PO3 Parunggao found an unlocked door, entered the premises, and, with PO2 Bautista, surprised the occupants. After identifying themselves as police, the officers arrested all four suspects.

Seizure of Evidence

• During the arrests, body searches revealed that among the arrested were the appellants, Jeric Pavia and Juan Buendia, from whom plastic sachets containing a white crystalline substance were confiscated.
• The confiscated items were marked by PO3 Parunggao—“JP” for Jeric Pavia and “JB” for Juan Buendia—and subsequently transmitted to the crime laboratory for qualitative analysis.
• Laboratory tests confirmed that the contents of the sachets were methylamphetamine hydrochloride (shabu).

Prosecution and Trial Proceedings

• The appellants were charged under Section 13, Article II of R.A. No. 9165 for illegal possession of dangerous drugs.
• At arraignment, both appellants pleaded not guilty, asserting that they were merely roaming and selling star apples and that a prospective buyer had invited them into his house. They contended that they were falsely arrested when police officers, posing as law enforcement, took them into custody.
• A joint trial ensued where the prosecution relied heavily on the detailed and credible testimony of PO2 Bautista, who testified about the manner in which the suspects were apprehended and the subsequent handling of the seized evidence.

Handling of Evidence and Chain of Custody

• The plastic sachets, along with visible drug paraphernalia in the house, were handled by the police officers under established procedures.
• PO2 Bautista and PO3 Parunggao’s testimony established that the items were marked at the police station before being turned over to the PNP Regional Crime Laboratory.
• The integrity and chain of custody of the seized evidence were maintained from the time of seizure until laboratory confirmation.

Lower Court Decisions

• The Regional Trial Court (RTC), Branch 31, San Pedro, Laguna, found the appellants guilty beyond reasonable doubt based on the spontaneous and credible evidence presented by the prosecution.
• On appeal, the Court of Appeals (CA) affirmed the RTC’s decision, holding that the warrantless arrest and subsequent search were lawful and that the prosecution had discharged its burden of proof.

Issue:

Legality of the Warrantless Arrest

• Whether the arrest of the appellants without a warrant constituted a violation of their rights or was justified by the circumstances of being caught in flagrante delicto.

Legality of the Search and Seizure

• Whether the bodily search of the appellants incident to their arrest was conducted lawfully and whether the items confiscated as a result could be admitted as evidence.

Preservation and Integrity of the Chain of Custody

• Whether the procedural shortcomings, particularly the alleged non-compliance with Section 21(1) of R.A. No. 9165, affected the integrity and admissibility of the seized evidence.

Credibility of the Defense Claims

• Whether the appellants’ version of events (claiming they were selling star apples and were framed) were supported by sufficient evidence to challenge the police testimony and the established chain of custody.

Evidentiary Sufficiency in Establishing Guilt

• Whether the evidence, including the positive laboratory results and the detailed, firsthand police testimony, met the standard of proof required for conviction beyond reasonable doubt.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)