Case Summary (G.R. No. 243313)
Background of the Case
On January 7, 2014, an information was filed against the petitioner alleging that on January 3, 2014, in San Pedro, Laguna, she illegally possessed drugs without lawful authority. The prosecution indicated that the police had seized two small sachets of methamphetamine hydrochloride from her during an operation based on a tip-off about drug activity in the area.
Prosecution's Version
Police Officer 2 Mateo F. Cailo provided testimony that he and another officer responded to reports of drug activity. Upon arriving at the location and conducting surveillance, they observed the petitioner allegedly with a sachet of shabu. After their interaction, they recovered additional illegal substances from her. Following proper documentation and a physical inventory, the drugs were sent to a crime laboratory, which confirmed the presence of methamphetamine.
Defense's Version
The petitioner claimed she was asleep in her house when the police entered and searched for her husband. She maintained her innocence, stating that the police did not respect her assertions that no drugs were present in her home and that they unlawfully seized items from her without proper procedure.
Trial Court's Judgment
The Regional Trial Court (RTC) of San Pedro City found the petitioner guilty, asserting that the prosecution had sufficiently proved its case and that procedural requirements under R.A. No. 9165 had been substantially complied with. The RTC sentenced her to a significant prison term and a hefty fine.
Court of Appeals Ruling
The petitioner appealed the conviction to the Court of Appeals (CA), which upheld the RTC's decision and ruled that any minor deviations in procedure did not undermine the integrity and evidentiary value of the evidence presented.
Core Legal Issue
The main issue presented to the Supreme Court was whether the conviction for illegal possession of dangerous drugs should be upheld, focusing particularly on the validity of the chain of custody of the evidence against the petitioner.
Supreme Court's Analysis
The Court emphasized that for a conviction under R.A. No. 9165, the prosecution must establish an unbroken chain of custody for the evidence in question. This involves monitoring and safeguarding the integrity of the seized items from the point of seizure through to its presentation in court. Failure to comply with Section 21 of R.A. No. 9165, which mandates specific procedures regarding the handling of seized drugs, can significantly undermine the case if such lapses are not justified.
Procedural Compliance and Witness Requirement
At the time of the offense, compliance with the witness requirements during the inventory was critical. The earlier version of Section 21 mandated the presence of elected officials, media repres
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Case Citation
- Jurisprudence: 866 Phil. 849
- G.R. No. 243313
- Date of Decision: November 27, 2019
Parties Involved
- Petitioner: Rosana Hedreyda y Lizarda
- Respondent: People of the Philippines
Procedural History
- The case is a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- The petitioner assails the Decision dated January 23, 2018, and Resolution dated November 13, 2018, of the Court of Appeals (CA) in CA-G.R. CR No. 39519.
- The CA's decision affirmed the Regional Trial Court (RTC) judgment dated December 7, 2016, which found the petitioner guilty of violating Section 11, Article II of Republic Act No. 9165, the Comprehensive Dangerous Drugs Act of 2002.
Facts of the Case
- On January 7, 2014, the petitioner was charged with Illegal Possession of Dangerous Drugs.
- The Information alleged that on January 3, 2014, in San Pedro, Laguna, the petitioner was found in possession of two small heat-sealed plastic sachets containing methamphetamine hydrochloride (shabu), weighing a total of 0.58 grams.
Prosecution's Version
- Police Officer 2 Mateo F. Cailo received a report of illegal drug activities and, with another officer, conducted surveillance at Amil Compound.
- At approximately 4:30 PM, they observed the petitioner examining a plastic sachet suspected to contain shabu.
- Upon approaching her, they identified themselves as police and asked her to empty her pockets, leading to the discovery of another sachet.
- The seized items were marked, subjected t