G.R. No. 217097 - Uy y Sayan vs. People

Petitioner Rolando Uy y Sayan alias “Nonoy” was charged by Information on May 28, 2004 with violation of Section 11, Article II of RA 9165 for illegal possession of 248 grams of marijuana flowering tops without government permit, aggravated by his positive drug use.
The case arose from events on April 6, 2004 at a mobile checkpoint in Sitio Pasok, Barangay Mabuhay, San Fernando, Bukidnon.

Around 5:45 p.m., PNP officers manning a COMELEC gun-ban checkpoint flagged down petitioner’s motorcycle and requested his CR and OR, which he failed to produce.
Upon inspecting the tools compartment and under the driver’s seat, officers found bundles of marijuana in cellophane wrappers. Petitioner was then brought to the police station where the seized marijuana tested positive in the PNP Crime Laboratory and his urine tested positive for marijuana use.

Petitioner denied knowledge of the drugs, testifying he was delivering medicines when his motorcycle had a flat tire. Armed men in civilian clothes searched his bag, found nothing, then arrested him for lack of documents.
He claimed he was beaten, extorted for ₱10,000, and coerced at the station; he alleged the search was conducted without a warrant and in violation of his rights.

RTC Decision (Nov. 17, 2010) convicted petitioner for illegal possession, emphasizing the presumption in favor of valid checkpoint searches and the absence of any permit to possess marijuana. Sentence: 12 years and 1 day to life, fine ₱400,000, with destruction of the 248 grams.
CA Decision (Aug. 8, 2014) affirmed with modification: held petitioner waived right to question arrest legality by not objecting pre-arraignment; struck down use evidence of urine test post-SJS v. Dangerous Drugs Board; imposed 12 years 1 day to 18 years 9 months, fine ₱300,000. CA Resolution (Feb. 9, 2015) denied reconsideration.
Petitioner filed a petition for review on certiorari before the Supreme Court, arguing violation of his right against unreasonable searches and failure to comply with chain-of-custody rules under RA 9165.

Whether the Court of Appeals erred in finding petitioner guilty beyond reasonable doubt of illegal possession of dangerous drugs under Section 11, Article II of RA 9165.
Whether the warrantless arrest and search at a mobile checkpoint were valid under the Constitution, Rule 113, Section 5, and relevant jurisprudential exceptions.
Whether the prosecution complied with the chain-of-custody requirements of Section 21, Article II of RA 9165, and its Implementing Rules and Regulations.