Title
Supreme Court
People vs. Laba y Samanoding
Case
G.R. No. 199938
Decision Date
Jan 28, 2013
Appellant caught at Manila Airport with 196.63g shabu concealed in shoes, convicted for transporting under RA 9165; SC upheld conviction, citing preserved chain of custody.

Case Summary (G.R. No. 199938)

Factual Background

On July 18, 2005, at approximately 10:45 AM, Villocillo frisked the appellant at the check-in area and felt suspicious material in his oversized white rubber shoes marked “Spicer.” Upon removal, three plastic sachets of suspected shabu—two in the left shoe, one in the right—were recovered. The appellant attempted to negotiate (“Baka pwedeng pag-usapan ito”) by offering cash. SPO2 Peji then formally arrested and read the appellant his rights; PO2 Caimoso conducted an onsite inquiry and handed over the appellant and sachets to arriving PDEA agents.

Laboratory Examination and Chemical Analysis

On July 18, 2005, PDEA requested laboratory testing of the three marked exhibits (weighing 98.81 g, 96.65 g, and 1.17 g). On July 19, 2005, Police Senior Inspector Ebuen performed a qualitative examination, confirming the total 196.63 g white crystalline substance as methylamphetamine hydrochloride (shabu).

Criminal Information and Plea

The appellant was charged with violating Section 5, Article II of RA 9165 for unlawfully transporting 196.63 g of shabu by concealing it in his shoes. He pled not guilty on June 27, 2005.

Appellant’s Defense

The appellant claimed entrapment and extortion by SPO2 Peji, alleged that officers planted the shabu, and denied ownership of the shoes. He also asserted that police demanded a ₱100,000 “settlement,” confiscated his cash, and forced a false admission.

Regional Trial Court Decision

On August 29, 2006, the RTC convicted the appellant, finding that:

  1. He was caught in flagrante delicto with physical possession and control of a large quantity of shabu.
  2. Testimonies of Villocillo and SPO2 Peji were credible, and officers were presumed to have performed their duties regularly.
  3. Appellant’s denials were unsupported and self-serving.
    Sentence imposed: life imprisonment, ₱500,000 fine (without subsidiary imprisonment), and costs.

Court of Appeals Ruling

On April 7, 2011, the CA affirmed in toto, holding that:

  • The identity of the seized substance was satisfactorily established.
  • Chain of custody—from seizure, marking, transport, and laboratory examination to court presentation—was properly maintained.
  • Failure to photograph and inventory under Section 21(1) of RA 9165 did not prejudice the substance’s integrity.
  • Non-presentation of the forensic chemist witness was not fatal, as the chemist’s report enjoys a presumption of regularity.

Issue on Appeal

Whether the RTC and CA committed reversible error in convicting the appellant for transporting shabu.

Statutory Provision on Transportation of Dangerous Drugs

Section 5, Article II of RA 9165 penalizes any unauthorized person who “transports” dangerous drugs with life imprisonment to death, and a fine of ₱500,000 to ₱10,000,000. “Transport” is defined as carrying or conveying a drug from one place to another.

Supreme Court’s Analysis on Transport Element

  • The appellant’s presence in the airport, awaiting a flight to Davao City with 196.63 g of shabu, satisfied the movement requirement inherent in “transport.”
  • Possession exceeding five grams raises a presumption of intent to traffic, not personal use.

Preservation of Evidence and Chain of Custody

  • The Court found no break in the chain of custody: seizure by Villocillo and SPO2 Peji, marking, PDEA custody, laboratory testing, and courtroom presentation.
  • Section 21(1) RA 9165’s inventory and photog

    ...continue reading

    Analyze Cases Smarter, Faster
    Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources.