Case Summary (G.R. No. 219590)
Factual Background
On the specified date, during a roving patrol, police officers, including SPO1 Metodio Aparis, observed the accused-appellant holding two transparent sachets that they suspected contained illegal drugs. Upon inquiry, the accused-appellant claimed that he was only asked to purchase shabu. The officers detained him, seized the sachets, and conducted a laboratory examination that confirmed the items contained methamphetamine hydrochloride, thereby leading to formal charges of drug possession against him.
Regional Trial Court Ruling
On April 16, 2010, the Regional Trial Court (RTC) ruled against the accused-appellant, finding him guilty beyond reasonable doubt of violating Section 11, Article II of RA 9165. He was sentenced to a term of imprisonment ranging from 12 years and one day to 13 years and ordered to pay a fine of 300,000 pesos. The decision also mandated the confiscation and destruction of the seized drugs.
Court of Appeals Ruling
The accused-appellant subsequently appealed to the Court of Appeals, which on July 31, 2013, upheld the RTC decision in its entirety, denying the appeal and affirming the conviction without further pronouncement as to costs.
Legal Issues Presented
The primary issues for resolution encompassed (1) the validity of the warrantless arrest and subsequent seizure of the accused-appellant's possessions and (2) whether the chain of custody for the seized evidence was maintained throughout the proceedings.
Court’s Ruling on Arrest and Seizure
In addressing the warrantless arrest, the court recognized that an arrest without a warrant may be lawful if the individual is committing, attempting to commit, or has just committed an offense in the presence of a law enforcement officer. The court concluded that the police officers adequately observed the accused-appellant engaged in suspicious behavior, thereby justifying the warrantless arrest as the illegal substances were plainly visible and he attempted to distance himself from liability when questioned.
Chain of Custody Considerations
Regarding the chain of custody, the court held that, while the prosecution's evidence handling process did not need to be flawless, substantial compliance with statutory requirements sufficed. It was noted that the
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Case Overview
- The case involves the appeal of accused-appellant Marcial M. Pardillo against the Decision dated July 31, 2013, from the Court of Appeals (CA) which affirmed his conviction for violating Section 11, Article II of Republic Act (RA) No. 9165, the Comprehensive Dangerous Drugs Act of 2002.
- The conviction was originally rendered by the Regional Trial Court (RTC) of Cebu City on April 16, 2010, in Criminal Case No. CBU-79099.
Background of the Case
- The events took place on February 2, 2007, around 3:00 PM, where police officers conducted a roving patrol in Barangay Suba, Cebu City.
- SPO1 Metodio Aparis, along with PO3 Macarinas and PO2 Tremaine Sotto, observed the accused-appellant holding two transparent sachets suspected to contain illegal drugs.
- Upon inquiry, the accused-appellant claimed he was merely asked to buy shabu.
- The police subsequently arrested him and seized the sachets, which later tested positive for methamphetamine hydrochloride.
Facts of the Case
- At the time of his arrest, the accused-appellant was in a location known for drug trafficking.
- The sachets were marked by SPO