G.R. No. 222187 , March 25, 2019
People of the Philippines, Plaintiff-Appellee, vs. Siegfredo Obias, Jr. y Arroyo a.k.a. “Boboy”, Accused-Appellant.

FACTS

The National Bureau of Investigation (NBI) Legaspi District Office, after surveillance and test-buy operations, secured search warrants for the rest house and cock farm of Siegfredo Obias, Jr. in Naga City. On September 13, 2008, a team composed of NBI agents, assisted by the PNP and PDEA, and witnessed by barangay officials, media representatives, and a prosecutor, served the warrants. During the search, the team found and seized several plastic sachets containing a white crystalline substance and various drug paraphernalia from different areas of the premises, including a bedroom, a kitchen, and a makeshift room. The search was documented via video and photographs. The seized items were marked, inventoried, and signed for by the witnesses present, although Obias refused to sign the inventory sheets. Forensic examination confirmed the substances were methamphetamine hydrochloride or shabu, with a total weight of 5.921 grams. Obias was subsequently charged with Illegal Possession of Dangerous Drugs and Illegal Possession of Drug Paraphernalia under Republic Act No. 9165 .
The Regional Trial Court convicted Obias of both charges, a decision affirmed by the Court of Appeals. On appeal to the Supreme Court, Obias argued that the search warrants were invalid for failing to particularly describe the place to be searched, claiming “Diamond Street, Villa Grande Homes Subdivision” was non-existent. He also contended the prosecution failed to establish an unbroken chain of custody over the seized items, alleging the marking was done by a person not part of the arresting team and that the inventory was not conducted at the place of seizure.

ISSUE

The core issues were: (1) whether the search warrants were valid despite the alleged incorrect address, and (2) whether the chain of custody over the seized drugs and paraphernalia was properly preserved to establish the integrity of the evidence.

RULING

The Supreme Court dismissed the appeal and affirmed the conviction. On the first issue, the Court ruled the search warrants were valid. The test for determining a warrant’s particularity is whether it enables the officer to locate the place to be searched with reasonable certainty. The warrants described the property as a “rest house and cock farm” owned by Obias at “Diamond Street, Villa Grande Homes Subdivision, Concepcion Grande, Naga City.” The executing officers, aided by prior surveillance, had no difficulty locating and searching the precise premises intended. The alleged misnomer of the street did not mislead the officers or invalidate the warrant, as the description was sufficient under the circumstances.
On the second issue, the Court held the chain of custody was substantially complied with, preserving the integrity and evidentiary value of the seized items. The prosecution established all crucial links: the items were immediately marked at the scene by NBI Special Investigator Manuel Mario B. Lanoza in the presence of Obias and witnesses; an inventory was prepared and signed by a barangay official, media representatives, and a prosecutor; the items were then submitted to the court and subsequently withdrawn for laboratory examination, where they tested positive for shabu. The defense failed to present evidence of tampering, bad faith, or ill motive. The Court emphasized that while the marking officer was not part of the initial search party, he was a member of the overall NBI team that conducted the operation, and his act of marking did not break the chain. The law does not require the inventory to be conducted precisely at the place of seizure, and the integrity of the proceedings was safeguarded by the presence of the required witnesses during the seizure and