G.R. No. 229183 - Quiap y Evangelista vs. People

On March 4, 2011, at approximately 10:30 a.m., PO2 Jerome Garcia received a phone call from a confidential asset following a person using the alias “Kacho.”
The asset informed the officer that “Kacho” was on his way to Sta. Cruz, Laguna, to procure shabu (methamphetamine hydrochloride) and later identified that he was riding in a jeepney with "Touch Mobile" signage bound for Calamba Crossing.
The asset provided a description of the suspect as a small, slightly bald man seated in front of him within the jeepney.

Based on the information received, the authorities organized an entrapment team composed of Police Senior Inspector Jefferson Parra-Ison, SPO1 Efren Sales, PO1 Ryan Virtrudes, and PO2 Garcia.
The team proceeded to a gasoline station along the National Highway in Barangay Labuin, Pila, Laguna, at around 10:55 a.m. to intercept the target vehicle.

Approximately five minutes later, the identified jeepney was flagged down by the police.
PO2 Garcia boarded the vehicle and focused on the man identified by the asset. During the encounter, the suspect was about to throw an object wrapped in electrical tape out of the jeepney window.
The officer promptly detained the suspect’s hand, requested him to unwrap the object, and discovered a small plastic sachet containing a white crystalline substance (shabu).
The sachet was confiscated on the spot and the suspect was then brought to the police station for further investigation.

At the police station, the suspect was identified as Leonides Quiap y Evangelista, later known as petitioner Leonides.
PO2 Garcia marked the confiscated sachet with “LQE-1” and handed it over to SPO1 Sales, who prepared a laboratory examination request.
The seizure evidence was delivered to the crime laboratory where SPO2 Macabajon took custody of the item, and thereafter, PSI Grace Bombasi conducted a qualitative examination that confirmed the presence of methamphetamine hydrochloride.

Subsequently, Leonides was charged with Illegal Possession of Dangerous Drugs under Section 11, Article II of Republic Act No. 9165, with Criminal Case No. SC-14520 filed against him.
Leonides denied the charge, contending that he was merely riding a jeepney home after visiting his cousin in Barangay Labuin, Pila, Laguna and that his subsequent arrest—following a stop, frisking, and forcible removal from the jeepney—was unlawful.
On May 28, 2015, the Regional Trial Court (RTC) convicted Leonides, affirming that his denial did not overcome the presumption of regularity in the performance of police duties and that the evidence’s integrity had been preserved.

Leonides elevated the case to the Court of Appeals (CA) under CA-G.R. CR No. 37675, questioning the validity of his arrest and alleging violations in the chain of custody of the dangerous drug evidence.
Specific points raised included:

The failure to mark the seized sachet immediately at the place of seizure.
The absence of insulating witnesses during the physical inventory and photographic documentation of the evidence.
The lack of proper receipt or record evidencing the turnover of the seized item.

The CA, on September 1, 2016, affirmed the RTC’s conviction by holding that any defect in the arrest was waived due to the absence of timely objection and that there was sufficient probable cause for the warrantless arrest, based on the “stop and frisk” rationale and the suspect’s suspicious behavior.

Whether Leonides’ arrest, conducted without a warrant, was valid under the circumstances given that he was allegedly apprehended in the act and during a “stop and frisk” operation.
Whether any alleged defects related to the execution of the arrest were properly raised at the proper stage of the proceedings.

Whether the proper procedures prescribed under Section 21, Article II of RA No. 9165 and its Implementing Rules and Regulations were followed in the management of the confiscated dangerous drug.
Whether the lapses—including failure to perform an immediate physical inventory with insulating witnesses, absence of photographic documentation, and the broken chain of custody between seizure and forensic examination—compromised the evidentiary integrity of the seized substance.

Whether the failure to maintain an unbroken chain of custody rendered the corpus delicti (i.e., the seized shabu) unreliable as evidence to sustain a conviction.