G.R. No. 196390 - Philippine Drug Enforcement Agency vs. Brodett

On April 13, 2009, the City Prosecutor of Muntinlupa City filed Criminal Case No. 09-208 against Richard Brodett and Jorge Joseph for violation of Section 5, in relation to Section 26(b) of R.A. No. 9165, alleging the sale of sixty (60) blue-colored tablets containing methamphetamine.
On April 16, 2009, Criminal Case No. 09-209 was filed against Brodett alone for violation of Section 11 of R.A. No. 9165, alleging possession of various quantities of MDMA (“Ecstasy”), cocaine, and THC.

During arrest, PDEA seized Brodett’s personal, non-drug effects—including a 2004 Honda Accord (plate no. XPF-551).
On July 30, 2009, Brodett moved in the RTC to return non-drug evidence, praying that his personal effects be submitted for verification and return.
On August 27, 2009, the City Prosecutor objected, proposing safekeeping of non-drug items pending trial and contending the car was an instrument of the drug transaction.
On November 4, 2009, the RTC ordered PDEA to photograph and return the Honda Accord to its registered owner, Myra S. Brodett, and to bring other personal effects for safekeeping.
PDEA’s motion for reconsideration was denied on February 17, 2010.
PDEA filed a certiorari petition in the Court of Appeals, which on March 31, 2011 dismissed it—holding that under Section 20 of R.A. No. 9165 properties of third persons not liable for the unlawful act are exempt from forfeiture.
PDEA appealed to the Supreme Court.

Whether a vehicle registered to a third person not charged with a drug offense is exempt from confiscation and forfeiture.
Whether Section 20 authorizes the release of such property pending trial and before judgment.

Whether a third-party owner must prove lack of knowledge of the crime to justify release.
Whether the RTC’s order violated the custodial requirements and due-process guarantees of Section 20.