Case Summary (G.R. No. 271012)
Antecedents and Initial Charges
On March 24, 2018, Padillo was accused of possessing illegal drugs, specifically methamphetamine hydrochloride, or "shabu." An Information was filed against him, accusing him of having multiple sachets of shabu weighing a total of approximately 51.7805 grams without the necessary legal authorization. Padillo pleaded not guilty, and trial proceedings commenced, involving testimonies from both the prosecution and defense.
Prosecution's Version of Events
The prosecution presented several witnesses, including forensic chemist Romelisa A. Ibale and various PDEA agents. Testimony indicated that a search warrant had been issued, allowing a team of PDEA agents to search Padillo's residence for illegal drugs. Despite attempts to announce their presence and authority, the agents entered the premises through the main door after Padillo did not respond. A search yielded multiple sachets containing shabu, which were seized in the presence of barangay officials and media representatives who documented the proceedings.
Defense's Version of Events
The defense presented a differing narrative, asserting that Padillo and his family were asleep when the PDEA agents forcibly entered the house. Padillo testified that the agents did not initially identify themselves adequately and that he only learned of the search warrant after he was ordered to vacate his room. Witnesses corroborated Padillo's claim but did not offer direct knowledge of the events occurring inside the master bedroom during the search.
Ruling of the Regional Trial Court
The Regional Trial Court ruled against Padillo, finding him guilty beyond a reasonable doubt. The court determined that the chain of custody for the seized drugs was established and favored the prosecution's testimonies, which were considered more credible compared to Padillo's denial of ownership and claims of planted evidence. Consequently, Padillo was sentenced to life imprisonment and fined two million pesos.
Ruling of the Court of Appeals
Padillo appealed to the Court of Appeals, which affirmed the RTC's decision, maintaining that the prosecution met its burden of proof regarding both the crime and the integrity of the chain of custody. The appellate court observed that the absence of certain witnesses did not undermine the overarching validity of the prosecution's evidence regarding the drug seizure.
Issues Raised
In his petition for review, Padillo raised three significant issues for resolution: (1) the validity of the search warrant; (2) the establishment of the chain of custody; and (3) whether his guilt was proven beyond a reasonable doubt.
Ruling of the Supreme Court
The Supreme Court found merit in Padillo's petition and ultimately acquitted him. The Court analyzed the search warrant’s issuance and execution, determining that the prosecuting authorities failed to adhere strictly to the constitutional requirements governing unreasonable searches and seizures. The lack of judicial inquiry into probable cause, as required by Article III, Section 2 of the Constitution, coupled with unclear justification for the nighttime execution of the warrant, invalidated the search.
Key Observations on Chain of Custody
Moreover, the Court highlighted significant lapses in the chain
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Case Background and Charges
- Roel Gementiza Padillo was charged under Section 11 of Republic Act No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002, for illegal possession of dangerous drugs.
- The charges stemmed from a search conducted on March 24, 2018, in Padillo's residence in Barangay Mantangale, Balingoan, Misamis Oriental.
- The police seized 14 sachets containing white crystalline substance (methamphetamine hydrochloride or "shabu") with a net weight of 51.7805 grams.
- Padillo pleaded not guilty and trial ensued.
Testimonies of the Prosecution
- Forensic Chemist Romelisa A. Ibale confirmed the seized substances tested positive for methamphetamine hydrochloride.
- PDEA agents (IO2 Tacal and IO2 Ancheta) testified on the planning, execution, and findings of the search operation, including the validation of the search warrant.
- Media representative Vernie G. Damolo and Barangay Chairman Alfred Vewalf Tan corroborated the events during the search (presence at search, witnessing inventory, and reading of the warrant).
- PDEA agents detailed the active entry into Padillo’s residence at night, announcement of authority, lack of response, forced entry, and discovery of illegal drugs in the master bedroom.
Version of the Defense
- Padillo and his witnesses testified to a different sequence of events, admitting the search but denying ownership of the seized drugs.
- They recounted the presence of PDEA agents, barangay officials, and media, but denied that any illegal drug possession was proven or that drugs were planted.
- The defense emphasized the alleged irregularities and inconsistencies during the search and evidence presentation.
Decision of the Regional Trial Court (RTC)
- The RTC found Padillo guilty beyond reasonable doubt of possession of methamphetamine hydrochloride.
- The chain of custody of the drug evidence was upheld as properly established.
- The RTC credite