G.R. No. 238873 , September 16, 2020
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. SUNDARAM MAGAYON Y FRANCISCO, DEFENDANT-APPELLANT.

FACTS

Appellant Sundaram Magayon was charged with illegal possession of dangerous drugs under Section 11, Article II of Republic Act No. 9165 . The prosecution evidence established that on August 3, 2004, police officers conducted a buy-bust operation at appellant’s residence in Butuan City. After witnessing the sale of a teabag of marijuana, the officers arrested appellant. Subsequently, citing a search warrant, they searched the premises in the presence of barangay officials and media personnel. The search yielded 276.9662 grams of dried marijuana fruiting tops and 104.3403 grams of marijuana stalks from various locations within the house. An inventory was conducted on-site, and the seized items were later examined and confirmed to be marijuana.
The defense presented a different version. Appellant testified that on the said date, he was at a neighbor’s house playing chess when several armed men arrived, forced him into his own home, and planted the marijuana evidence. He claimed the search was conducted without a warrant and that he was coerced into signing a document. The trial court convicted appellant, a decision affirmed by the Court of Appeals, prompting this final appeal.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction for illegal possession of dangerous drugs.

RULING

The Supreme Court affirmed the conviction. The Court held that all elements of illegal possession were proven: appellant was in possession of a prohibited drug without legal authority, and he freely and consciously possessed it. The Court found the defense of frame-up unconvincing and inherently weak, as it was not substantiated by clear and convincing evidence. Appellant failed to demonstrate any ill motive on the part of the police officers to falsely accuse him.
Crucially, the Court ruled that the legality of the warrantless arrest following the buy-bust was immaterial to the prosecution for possession. The drugs subject of the possession charge were not seized from appellant’s person during the arrest but were discovered subsequently during a search conducted pursuant to a validly issued warrant. The search warrant, applied for earlier that day after a test buy, was implemented properly in the presence of the required witnesses. The chain of custody of the evidence seized under this warrant was also preserved. Therefore, the items seized from the house were admissible, and the conviction for illegal possession based on these items must stand. The appeal was denied.