Title
People vs. Uy y Ting
Case
G.R. No. 250307
Decision Date
Feb 21, 2023
Accused acquitted due to prosecution's failure to prove drug charges and preserve evidence integrity, extending acquittal to co-accused.

Case Summary (A.M. No. MTJ-96-1112)

Applicable Law

Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) • Section 5 (transportation/delivery of dangerous drugs) • Section 11 (possession of dangerous drugs) • Section 21 (chain of custody requirements)

Criminal Case No. 1179-V-03 (Section 5, RA 9165)

Allegation: On November 10, 2003, Uy allegedly drove a Mitsubishi Lancer loaded with a box containing five plastic bags of white crystalline substance (approx. 9,384.7 g “shabu”) from a warehouse in Valenzuela City toward a designated pick-up point, without lawful authority.

Criminal Case No. 1180-V-03 (Section 11, RA 9165)

Allegation: On November 11, 2003, pursuant to a search warrant, anti-drug operatives recovered from a Mapulang Lupa warehouse leased by Willie Gan—where Uy occasionally assisted—119.080 kg of methamphetamine hydrochloride and 111.200 kg of chloromethamphetamine hydrochloride, without license or authority.

RTC Ruling (June 30, 2014)

• Convicted Uy of both offenses: – Life imprisonment + ₱500,000 fine (Sec. 5) – 12 years 1 day to 14 years 8 months + ₱300,000 fine (Sec. 11)• Convicted Gan of Sec. 11; acquitted other co-accused on demurrer to evidence• Reasoning: – Uy was caught in flagrante delicto transporting and delivering the “shabu.” – Possession by Gan as lessee of the warehouse established.

CA Ruling (April 25, 2019)

• Affirmed RTC verdict with modification of penalty for Sec. 11 (life imprisonment + ₱10 million fine, given volume of drugs)• Key determinations: – Entrapment not established; transport of shabu was malum prohibitum. – Warrantless arrest valid (flagrante delicto). – Chain of custody sufficiently preserved despite absence of DOJ representative.

Issues on Appeal

  1. Whether Uy was merely instigated into transporting the shabu.
  2. Whether evidence was inadmissible as fruits of an illegal arrest/search.
  3. Whether elements of Sec. 5 and Sec. 11 offenses were present.
  4. Whether conspiracy was proven.
  5. Whether Sec. 21 (chain of custody) and IRR procedures were violated, invalidating corpus delicti.

Supreme Court’s Analysis (1987 Constitution Basis)

  1. Failure to Prove Delivery Intent (Sec. 5)
    – Transport of dangerous drugs is malum prohibitum, yet “animus possidendi” must be shown by circumstances.
    – Uy’s consistent account: he was hired as a part-time driver, had no prior contact with the drugs, and followed instructions without knowing contents of the box.
    – Equipoise rule: when facts allow an interpretation consistent with innocence, the prosecution fails to establish moral certainty.

  2. Failure to Prove Possession (Sec. 11)
    – Actual possession impossible: Uy was in custody at time of warehouse search.
    – Constructive possession requires dominion and control over the warehouse; Uy had none (lessee was Gan).

  3. Chain of Custody Lapses (Sec. 21, RA 9165)
    – Mandatory inventory and photography “immediately after seizure,” witnessed by (1) the accused or representative, (2) a media rep., (3) DOJ rep., and (4) elective official.
    – November 10 operation: no Inventory Receipt; marking unclear; no insulating witnesses present for inventory/photography.
    – November 11 operation: absent DOJ rep.; inventory receipt not in evidence; photograp

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