G.R. No. 242315 . July 3, 2019.
RIEL ARANAS y DIMAALA, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

This case stemmed from an Information charging petitioner Riel Aranas y Dimaala with Illegal Possession of Dangerous Drugs under Section 11, Article II of Republic Act No. 9165 . On May 13, 2015, police officers implemented a search warrant at petitioner’s residence. During the search, they found two plastic sachets of suspected shabu inside a Katialis ointment container, along with a rolled aluminum foil and a lighter. After arresting petitioner, the officers marked, inventoried, and photographed the seized items at the place of arrest in the presence of petitioner, Barangay Chairman Aileen Mendoza (an elected public official), media representative Benedicto Griño, and Department of Justice representative Judith Buhay. The items were then brought to the police station, and a request for laboratory examination was prepared. The seized sachets were delivered to the crime laboratory, where examination confirmed the presence of methamphetamine hydrochloride or shabu. Petitioner interposed the defense of denial, claiming the police officers barged into his house and searched it without consent, later finding illegal drugs.
The Regional Trial Court found petitioner guilty beyond reasonable doubt and sentenced him to an indeterminate penalty of imprisonment and a fine. The Court of Appeals affirmed the conviction, ruling that the integrity and evidentiary value of the seized drugs were preserved and the chain of custody remained unbroken.

ISSUE

Whether the Court of Appeals erred in affirming petitioner’s conviction for Illegal Possession of Dangerous Drugs, particularly regarding the establishment of the elements of the crime and compliance with the chain of custody rule under Section 21 of RA 9165, as amended.

RULING

The Supreme Court denied the petition and affirmed the conviction. The Court ruled that all elements of Illegal Possession of Dangerous Drugs were proven beyond reasonable doubt: (a) petitioner was in possession of prohibited drugs recovered via a valid search warrant; (b) such possession was not authorized by law; and (c) petitioner freely and consciously possessed the drugs, as they were hidden inside an ointment container. The trial court’s assessment of witness credibility was accorded respect.
Furthermore, the police officers sufficiently complied with the chain of custody rule under Section 21 of RA 9165, as amended by RA 10640. The marking, inventory, and photography of the seized items were conducted immediately after seizure and confiscation at the place of arrest in the presence of the required witnesses: an elected public official (Barangay Chairman), a media representative, and a DOJ representative. The seized items were then delivered to the forensic chemist for examination and subsequently turned over to the evidence custodian for safekeeping. Thus, the chain of custody remained unbroken, and the integrity and evidentiary value of the corpus delicti were properly preserved. Petitioner’s conviction was upheld.