Title
Reyes y Capistrano vs. People
Case
G.R. No. 229380
Decision Date
Jun 6, 2018
Leniza Reyes acquitted by Supreme Court due to invalid warrantless arrest and failure to establish chain of custody in illegal drug possession case.

Case Digest (G.R. No. 229380)
Expanded Legal Reasoning Model

Facts:

  • Charge and Circumstances of Arrest
    • On November 6, 2012, petitioner Leniza Reyes y Capistrano was charged with illegal possession of 0.04 gram of methamphetamine hydrochloride (shabu) in Cardona, Rizal, in violation of Section 11, Article II of RA 9165.
    • At around 8:00 PM, Police Officer 1 (PO1) Jefferson Monteras, while patrolling with colleagues in Barangay Looc, received a tip from two teenagers about a woman with long hair and a dragon tattoo who had just bought shabu in Barangay Mambog. They encountered Reyes—who smelled of liquor—asked if she had shabu, and she allegedly turned, retrieved a heat-sealed sachet from her breast area, and handed it over.
  • Procedural History
    • The seized sachet was marked “LRC-1,” inventoried and photographed before Barangay Captain Manolito Angeles, then submitted to the Rizal Provincial Crime Laboratory, which confirmed it contained 0.04 gram of methamphetamine hydrochloride.
    • In RTC Crim. Case No. 12-0627, Branch 67, Binangonan, Rizal, the trial court (June 16, 2014) convicted Reyes of possessing 0.11 gram of shabu, sentencing her to 12 years and 1 day to 13 years imprisonment and a P300,000 fine.
    • On appeal, the Court of Appeals (CA) (May 20, 2016) affirmed the conviction, adjusted the quantity to 0.04 gram, and modified the penalty to 12 years and 1 day to 14 years and 8 months. A motion for reconsideration was denied (January 11, 2017).

Issues:

  • Whether Reyes’s conviction for Illegal Possession of Dangerous Drugs under Section 11, Article II of RA 9165 should be upheld despite alleged defects in her warrantless arrest, search, and chain of custody.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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