G.R. No. 177191 - San Juan y Cruz vs. People

Case Summary (G.R. No. 177191)

Facts of the Case

On December 15, 2003, petitioner Michael San Juan y Cruz, together with co-accused Pineda and Coderes, were charged with transporting 978.7 grams of methamphetamine hydrochloride (shabu), a dangerous drug, in violation of Section 5, Article II of R.A. No. 9165. The event occurred in Pasay City. The accused pled not guilty during arraignment. The prosecution and the accused presented differing versions of the circumstances of their arrest and the seizure of the drugs.

Prosecution’s Version

The Pasay City Police Intelligence Unit conducted surveillance along Senator Gil Puyat Avenue due to reports of criminal activity. Police officers in civilian clothing noticed a blue Toyota Corolla without a rear license plate parked in front of a liquor store. Upon approaching, they found petitioner driving the car, with Pineda and Coderes as passengers. Pineda was seen attempting to hide a plastic bag under his seat, which contained white crystalline substances suspected to be shabu. When petitioner was frisked, police recovered additional plastic sachets containing similar substances. Coderes identified a Mike waiting at her condominium unit (Unit 1225, 12th Floor, Cityland Condominium, Makati City) as the owner of the drugs.

Police went to the condominium with the accused and the car for a follow-up operation. Coderes entered the unit alone, then locked herself inside. Police forcibly opened the door, found no other person inside, and arrested her again. All accused were brought to the Pasay City Police Headquarters for further investigation. The seized substances tested positive for methamphetamine hydrochloride.

Defense’s Version

Pineda and Coderes denied that they were arrested inside the car or that they possessed the drugs. They asserted that they were inside the condominium unit preparing to go shopping when police men forcibly entered without a search or arrest warrant, subjected them to a search, confiscated valuables, and detained them in the Sinta Court Motel. They claimed that the police officers demanded money for their release. Petitioner stated he was waiting at the condominium lobby to offer the car for sale and was forcibly taken by police officers in civilian clothing without being informed of their identities or charges. He outlined that he was handcuffed, subjected to illegal detention, and extorted for P200,000.

RTC Ruling

The RTC found the prosecution’s testimonies credible and convincing beyond reasonable doubt. It convicted petitioner and co-accused of violating Section 5, Article II of R.A. No. 9165, sentencing them to life imprisonment and imposing a fine of Php 500,000 each. The RTC ordered forfeiture of the seized drugs to the Philippine Drug Enforcement Agency (PDEA). The decision was subsequently affirmed by the Court of Appeals.

Court of Appeals Ruling

The CA affirmed the RTC’s decision, holding that inconsistencies in police officers’ testimonies were immaterial and did not affect the prosecution’s proof beyond reasonable doubt. The CA relied on the presumption that police officers acted regularly in the performance of their duties. It denied the accused’s motion for reconsideration.

Issues Raised by Petitioner on Petition for Review

Petitioner argued reversible errors including unconstitutional admission of evidence, conflicting and inconsistent testimonies of prosecution witnesses, violation of procedural rules and constitutional rights by denying petitioner the opportunity to present a material witness, illegal search and arrest without warrant or probable cause, failure to inform accused of their rights, unlawful follow-up operation in Makati without a search warrant, deviation from the prescribed procedure under R.A. No. 9165, risk of planting evidence, and failure of police to conduct a proper inventory of seized items.

Government’s Position

The Office of the Solicitor General maintained that only questions of law are within the appellate court’s jurisdiction and disputed the factual claims of illegal apprehension. The OSG contended that petitioner was caught in flagrante delicto, making the seizure and custody of evidence lawful. It asserted that the police officers’ testimonies were clear and trustworthy, and underscored the finality of lower court findings affirmed by the CA.

Supreme Court’s Analysis on Procedure Under R.A. No. 9165 and Its IRR

Section 21 of R.A. No. 9165 and its Implementing Rules and Regulations require the apprehending team to perform an immediate physical inventory and photography of seized dangerous drugs in the presence of the accused or their counsel, media representatives, DOJ representatives, and elected public officials. The inventory and photograph documents must be signed by the attendees, who are also to receive copies. This process aims to maintain the integrity and evidentiary value of the seized items.

Failure to Comply with Inventory and Chain of Custody Requirements

The police officers failed to perform a proper, written inventory and photograph of the seized drugs immediately after the confiscation. Testimony revealed that no written inventory was made, no photographs were taken, and copies of any inventory were never given to the accused or required witnesses. The prosecution did not present justifiable grounds to excuse such non-compliance, nor did it satisfactorily establish the chain of custody of the seized items.

The apprehending officers’ failure to clarify to whom the initial custody of the drugs was turned over, how they were transferred to the forensic chemist, or how they were safeguarded between examination and presentation in court left a significant break in the chain of custody. This failure undermined the prosecution’s proof of the identity and integrity of the corpus delicti (the illegal drugs).

Impact of Illegal Search and Detention Allegations

The Supreme Court also noted irregularities in procedure, including the delay in bringing the accused to the police station and the conduct of a follow-up operation at the condominium, which risked tampering, substitution, or planting of evidence. The police officers were

Case Syllabus (G.R. No. 177191)

Background and Nature of Petition

The Supreme Court reviews a Petition for Review on Certiorari under Rule 45 from the Court of Appeals (CA) decision affirming the Regional Trial Court (RTC) of Pasay City’s conviction of petitioner Michael San Juan y Cruz, co-accused Rolando Pineda y Robledo and Cynthia Coderes y Habla for violation of Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
The accused were charged with transporting 978.7 grams of Methylamphetamine Hydrochloride (shabu), a dangerous drug, without authority of law.
The RTC and later the CA found the accused guilty beyond reasonable doubt; petitioner challenges these rulings invoking violations of constitutional rights and procedural lapses under R.A. No. 9165.

Facts of the Case

On December 15, 2003, Pasay City police officers in civilian clothes conducted surveillance along Senator Gil Puyat Avenue in Pasay, an area with reports of crime.
Three police vehicles were involved; officers noticed a blue Toyota Corolla with no rear license plate parked in front of a liquor store.
Police approached the vehicle; the driver was identified as petitioner, with Pineda and Coderes as passengers.
Upon interaction, the police found plastic sachets of suspected shabu under a passenger’s seat and on petitioner’s person.
Coderes indicated the shabu owner was “Mike” waiting at her condominium Unit 1225, 12th Floor, Cityland Condominium, Makati City.
The police, along with the accused and the seized car and illegal drugs, proceeded to Cityland Condominium for follow-up operation.
Coderes forcibly entered Unit 1225, locking herself inside; police broke in and found no one but Coderes.
All accused were taken to Pasay City Police Headquarters; subsequent chemical tests confirmed the substance as shabu.

Defense Version

Pineda and Coderes denied possession and claimed they were inside Unit 1225 preparing to shop when police forcibly entered without warrants, searched them, and took their belongings.
They alleged illegal detention at Sinta Court Motel where police demanded P500,000 for release and were brought to the Criminal Investigation Division (CID) later the same day.
Petitioner testified that earlier on the day in question, he was waiting at Cityland Condominium to meet Pineda and Coderes for a car sale and that police forcefully arrested him without introducing themselves, handcuffed him, robbed him of valuables, and detained him for hours.
Petitioner asserted police demanded P200,000 for his release and that the car used during the supposed arrest had proper permit documents.

RTC Decision

The RTC credited the testimonies of arresting police officers as more credible and convicted petitioner and co-accused of violating R.A. No. 9165.
Penalties imposed included life imprisonment and a fine of Php 500,000 each.
The seized drugs were forfeited in favor of the government, turned over to the Philippine Drug Enfor