Case Summary (G.R. No. 229380)
Petitioner
Leniza Reyes y Capistrano
Respondent
People of the Philippines
Key Dates
• November 6, 2012 – Alleged seizure and arrest
• June 16, 2014 – RTC of Binangonan, Rizal decision
• July 9, 2014 – Notice of appeal to the Court of Appeals
• May 20, 2016 – CA Decision affirming conviction (modified quantity and penalty)
• January 11, 2017 – CA Resolution denying reconsideration
• June 6, 2018 – Supreme Court Decision
Applicable Law
• 1987 Philippine Constitution, Article III, Sections 2 and 3(2) (unreasonable searches and seizures)
• Section 11, Article II of Republic Act No. 9165 (illegal possession of dangerous drugs)
• Rule 113, Section 5(a)–(b) of the Revised Rules of Criminal Procedure (warrantless arrest)
• Section 21, Article II of RA 9165 (chain of custody requirements)
The Facts
Reyes was allegedly approached by officers after matching a general description from a tip. When asked if she had bought shabu, she is said to have turned her back and displayed a plastic sachet containing 0.04 gram of methamphetamine hydrochloride. The sachet was marked “LRC-1,” inventoried, photographed before the barangay captain, and sent for laboratory confirmation. Reyes disputed the date, alleged extortion by officers, and denied possession.
RTC Decision
The Regional Trial Court found Reyes guilty beyond reasonable doubt of illegal possession, convicted her for 0.11 gram of shabu, sentenced her to an indeterminate term of 12 years 1 day to 13 years’ imprisonment, and imposed a ₱300,000 fine. The RTC held that the arrest and search were lawful and that the chain of custody was satisfactorily maintained.
Court of Appeals Decision
The Court of Appeals affirmed the conviction but corrected the quantity to 0.04 gram, adjusting the penalty to 12 years 1 day to 14 years 8 months. It upheld the warrantless arrest under flagrante delicto, validated the search as incidental to that arrest, and found substantial compliance with the chain of custody rule.
Issue Before the Supreme Court
Whether Reyes’s conviction for illegal possession of dangerous drugs under Section 11, Article II of RA 9165 should be upheld, given alleged defects in the arrest, search, and chain of custody.
Supreme Court Ruling
The Supreme Court granted the petition, ruling that the warrantless arrest and search were unconstitutional under the 1987 Constitution and that the seized evidence was inadmissible as fruit of the poisonous tree. It also found unjustified deviations from the chain of custody requirements of RA 9165. Accordingly, Reyes’s conviction was reversed and she was acquitted.
Arrest and Search Analysis
Under Rule 113, Section 5, a warrantless arrest requires either (a) commission of a crime in the presence of the arresting officer or (b) personal knowledge of facts indicating a just-committed offense. PO1 Monteras testified that Reyes merely passed by, smelled of liquor, and performed no overt act suggesting possession. His reliance on an unverified tip failed to establish either in-presence commission or personal knowledge. Without lawful arrest, the subsequent search and seizure were unreasonable and violated Article III, Sections 2 and 3(2) of the 1987 Constitution.
Credibility of Testimony
The Court noted the improbability that Reyes would voluntarily exhibit incriminating evidence absent coercion. The Office of the Solicitor General’s inconsistent asse
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Facts
- On November 6, 2012 at around 8:00 PM, Police Officer 1 Jefferson Monteras and a patrol group in Cardona, Rizal, were informed by two teenagers that a woman with long hair and a dragon tattoo on her left arm had just purchased shabu in Barangay Mambog.
- A woman matching that description—later identified as petitioner Leniza Reyes y Capistrano—passed by the officers on the diversion road, smelling of liquor but not acting suspiciously.
- Upon being questioned about the shabu, Reyes allegedly turned her back, retrieved a heat-sealed transparent plastic sachet from her brassiere, and presented it to the officers.
- PO1 Monteras marked the seized sachet “LRC-1,” conducted inventory and photography before Barangay Captain Manolito Angeles, and submitted the item to the Rizal Provincial Crime Laboratory.
- The chemistry report confirmed the sachet contained 0.04 gram of methamphetamine hydrochloride, a dangerous drug.
- Reyes contended the incident occurred on November 5, 2012; that armed men identifying themselves as police extorted ₱35,000.00 from her; and that she never possessed any illegal substance.
Petition and Procedural History
- RTC, Binangonan, Rizal (Branch 67) Decision dated June 16, 2014:
- Found Reyes guilty beyond reasonable doubt of illegal possession of 0.11 gram of shabu (erroneously stated) under Section 11, Article II of RA 9165.
- Imposed an indeterminate penalty of 12 years and 1 day to 13 years, plus a ₱300,000.00 fine.
- Court of Appeals Decision dated May 20, 2016:
- Affirmed conviction, validated the in flagrante delicto arrest and chain of custody.
- Corrected the quantity to 0.04 gram to align with laboratory findings.
- Modified the penalty to 12 years and 1 day to 14 years and 8 months.
- Supreme Court Recourse:
- Reyes file