G.R. No. 224039, September 11, 2019
DANILO DE VILLA Y GUINTO, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

On May 4, 2011, police officers from Tuy, Batangas were conducting a checkpoint in Barangay Rizal. They flagged down a motorcycle driven by accused-appellant Danilo De Villa y Guinto, with his wife as a backrider, for traffic violations (not wearing a helmet and shoes, vehicle without an attached license plate). When asked for registration papers, Danilo opened the motorcycle’s utility box, where PO2 Salanguit saw two plastic sachets containing white crystalline substance. The officers then bodily searched Danilo and recovered two more plastic sachets from his right pocket. The four seized sachets were marked, inventoried at the barangay hall in the presence of a DOJ representative, a media representative, and the barangay chairman, and subsequently submitted for forensic examination, which yielded a positive result for methamphetamine hydrochloride (shabu). Danilo was charged with illegal possession of dangerous drugs under Section 11(3), Article II of Republic Act No. 9165. He pleaded not guilty and claimed frame-up, alleging the drugs were planted and that the police did not coordinate with the Philippine Drug Enforcement Agency (PDEA).

ISSUE

Whether Danilo De Villa y Guinto’s guilt for violation of Section 11(3) of RA 9165 (Illegal Possession of Dangerous Drugs) was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found that all elements of illegal possession were proven: (1) Danilo was in possession of four plastic sachets of shabu; (2) such possession was not authorized by law; and (3) he freely and consciously possessed the drug. His warrantless arrest was valid as he was caught in flagrante delicto committing a crime (possession of illegal drugs) in plain view of the officers during a routine checkpoint. The subsequent search and seizure were incidental to a lawful arrest. The police officers complied with the chain of custody rule under Section 21 of RA 9165, as the inventory was conducted in the presence of the required witnesses. The defense of frame-up was not substantiated by clear and convincing evidence. Furthermore, the non-participation of the PDEA does not invalidate the arrest or seizure, as RA 9165 does not designate PDEA as the sole agency for enforcing drug laws. The concurrent factual findings of the Regional Trial Court and the Court of Appeals, which found the testimonies of the prosecution witnesses credible and the integrity of the evidence preserved, were upheld.