Case Digest (G.R. No. 131856-57)
Facts:
In People of the Philippines v. Paulo Jackson Polangcos y Francisco (G.R. No. 239866, September 11, 2019), an Information was filed in the Regional Trial Court (RTC) of Marikina City, Branch 263, charging Polangcos with violation of Section 11, Article II of Republic Act No. 9165 (the Comprehensive Dangerous Drugs Act of 2002). It alleged that on August 16, 2015 at around 6:40 p.m. in Marikina City, SPO2 Juntanilla, while issuing Polangcos a traffic citation for driving a motorcycle without a plate number and with expired registration documents, frisked him and recovered a plastic sachet containing 0.05 gram of white crystalline substance suspected to be shabu. The item was marked “PJP-1 08-16-15,” inventoried in the presence of a barangay kagawad, and submitted to the crime laboratory, which tested positive for methamphetamine hydrochloride. Polangcos pleaded not guilty; he did not testify or present evidence. On November 2, 2016, the RTC convicted him to 12 years and 1 day toCase Digest (G.R. No. 131856-57)
Facts:
- Criminal Charge and Trial
- An Information was filed on August 16, 2015, against Paulo Jackson F. Polangcos for violation of Section 11, Article II of RA 9165 (possession of 0.05 g of methamphetamine hydrochloride).
- At arraignment, Polangcos pleaded not guilty. Subsequent pre-trial and trial on the merits followed before RTC Branch 263, Marikina City.
- Prosecution’s Version
- SPO2 Rey J. Juntanilla, on mobile patrol along J.P. Rizal St., Marikina City, spotted Polangcos driving a green RACAL motorcycle without a plate number and with expired OR/CR. He pursued and allegedly arrested Polangcos for the city ordinance violation.
- During a body frisk—conducted before issuance of the ordinance violation receipt—a plastic sachet fell from Polangcos’ cap; it was marked “PJP-1 08-16-15,” inventoried before Brgy. Kagawad Rogel Santiago, and submitted via PO2 Diola to PCI Margarita Libres. Laboratory report confirmed the sachet contained methamphetamine hydrochloride.
- Defense
- The defense presented no witnesses or evidence; Polangcos was absent during the scheduled presentation of defense evidence.
- The case was submitted for decision.
- Lower Court Rulings
- RTC Decision (Nov. 2, 2016): Convicted Polangcos of illegal possession of dangerous drugs; sentenced him to 12 years & 1 day to 20 years imprisonment and P300,000 fine, relying on presumption of regularity and a non-fatal chain-of-custody break.
- CA Decision (Mar. 28, 2018) and Resolution (June 7, 2018): Affirmed conviction, holding that (a) all elements of the crime were proven; (b) preservation of evidentiary value outweighed technical chain-of-custody lapses; and (c) objections to warrantless arrest and search should have been raised before arraignment.
Issues:
- Whether Polangcos was validly arrested and legally searched under the Constitution and RA 9165.
- Whether the seized drug evidence was admissible, in light of chain-of-custody requirements and the exclusionary rule.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)