Case Summary (G.R. No. 234207)
Petitioner
People of the Philippines
Respondent
Marlon Cristobal y Ambrosio
Key Dates
- November 21–22, 2013: Alleged seizure of shabu
- December 14, 2015: RTC conviction
- June 29, 2017: CA affirmed conviction
- June 10, 2019: Supreme Court decision
Applicable Law
- 1987 Constitution (Art. III, Secs. 2–3[2]: protection against unreasonable searches and seizures)
- RA 9165, Sec. 11, Art. II (possession of dangerous drugs)
- RA 10054 (penalties for motorcycle helmet violation)
- LTO Dept. Order No. 2008-39 (penalty for failure to carry OR/CR)
Facts
- At a Pasig City checkpoint, Cristobal was stopped for riding without a helmet and failing to produce OR/CR.
- While awaiting a citation ticket, he allegedly fled but was apprehended.
- PO2 Ramos frisked Cristobal for weapons (found none) but discovered a bulge in his pocket.
- Under order, Cristobal retrieved seven sachets of white crystalline substance later confirmed as methamphetamine hydrochloride.
- Seized items underwent proper marking, inventory before a barangay witness, transfer to crime lab for testing, and custody by the evidence custodian.
Procedural History
- RTC found Cristobal guilty of illegal possession under RA 9165, sentencing him to 20 years and one day to life imprisonment plus a ₱400,000 fine.
- CA affirmed, rejecting Cristobal’s denial and upholding evidentiary integrity despite procedural lapses.
Issue
Whether the warrantless search and seizure were lawful under the Constitution and RA 9165.
Supreme Court Ruling
- Constitution applies (decision date post-1990).
- No lawful arrest: Helmet and OR/CR violations carry fines only, prohibiting warrantless arrest or incidental search.
- Stop-and-frisk doctrine inapplicable:
- Officers admitted finding no weapon.
- Search continued beyond a limited outer-clothing pat-down for weapons.
- Lacked
Case Syllabus (G.R. No. 234207)
Facts
- On November 21, 2013, in Pasig City, Marlon Cristobal y Ambrosio was flagged down at a police checkpoint for riding a motorcycle without a helmet.
- He failed to present the original receipt (OR) and certificate of registration (CR) of the motorcycle; he showed only his driver’s license.
- While an officer was preparing a traffic citation ticket, Cristobal attempted to flee but was apprehended by other officers.
- PO2 Ramos frisked him for weapons, found nothing, but noticed a bulge in his pocket.
- Cristobal was ordered to empty his pockets and produced a small plastic bag containing seven heat-sealed sachets of white crystalline substance (total weight 5.96 g).
- The sachets were marked, inventoried in the presence of a barangay kagawad and Cristobal, and then processed under the chain of custody.
- Forensic examination by PSI Anghelisa Santiago confirmed the substance as methamphetamine hydrochloride (“shabu”).
- The seized items were released for court presentation on April 10, 2014.
Procedural History
- RTC Pasig City, Branch 154 (Crim. Case No. 18885-D-PSG): Convicted Cristobal on December 14, 2015 for violating Sec. 11, Art. II, RA 9165; sentenced to 20 years and 1 day to life plus a ₱400,000 fine.
- Court of Appeals (CA-G.R. CR-HC No. 08134): Affirmed RTC decision on June 29, 2017.
- Supreme Court (G.R. No. 234207): Review on appeal filed by Cristobal; decision rendered June 10, 2019.
Issue
- Whether the RTC and the CA erred in convicting C