G.R. No. 256233 , August 09, 2023
People of the Philippines, Plaintiff-Appellee, vs. Nixon Cabanilla y Crisologo, Michael Cabardo y Cordevilla, and Gomer Valmeo y Comilang, Accused-Appellants.

FACTS

Accused-appellants Nixon Cabanilla, Michael Cabardo, and Gomer Valmeo were charged with violations of Section 13 (Possession of Dangerous Drugs During Parties, Social Gatherings or Meetings) and Section 14 (Possession of Equipment, Instrument, Apparatus and Other Paraphernalia for Dangerous Drugs) of Republic Act No. 9165 . The prosecution alleged that on January 29, 2017, police officers on patrol in San Juan City saw Nixon half-naked inside a parked jeepney, which violated a local ordinance. When the officers approached to verify his identity, they allegedly saw drug paraphernalia scattered on the vehicle’s floor, leading to the arrest of all three accused and the seizure of items including plastic sachets containing white crystalline substance (later confirmed as methamphetamine hydrochloride), an improvised tooter pipe, aluminum foil, lighters, and surgical scissors. The accused pleaded not guilty and claimed they were arrested while Nixon was resting and the others were borrowing tools, with Nixon wearing a jacket, not half-naked. The Regional Trial Court convicted them, and the Court of Appeals affirmed the conviction. The accused appealed to the Supreme Court, arguing inconsistencies in the prosecution’s testimonies and non-compliance with the chain of custody rule.

ISSUE

Did the accused violate Section 13 of Republic Act No. 9165 , as amended?

RULING

No. The Supreme Court acquitted the accused-appellants. The Court ruled that the warrantless arrest and search were invalid. The police officers’ initial approach, purportedly due to a violation of a local ordinance against being half-naked in public, did not justify the subsequent search and seizure. The accused were not caught in flagrante delicto, as the officers did not personally witness any ongoing crime before boarding the jeepney. The search that revealed the alleged drugs and paraphernalia was therefore unlawful, and the evidence obtained is inadmissible. Furthermore, the prosecution failed to establish an unbroken chain of custody of the seized items, noting discrepancies such as the description of a sachet as “heat-sealed” when it was allegedly already open upon confiscation. The Court emphasized that the constitutional guarantee against unreasonable searches and seizures must be upheld, and all doubts should be resolved in favor of the accused.