G.R. No. 175604 ; April 10, 2008
THE PEOPLE OF THE PHILIPPINES, appellee, vs. SALVADOR PEÑAFLORIDA, JR. Y CLIDORO, appellant.

FACTS

Appellant Salvador Peñaflorida, Jr. was charged with violating Section 4, Article II of R.A. No. 6425 (The Dangerous Drugs Act) for transporting marijuana. The prosecution evidence established that on June 7, 1994, police officers in Tigaon, Camarines Sur, acting on a tip, intercepted appellant who was riding a bicycle. Upon inspection, they found a bundle containing 928 grams of dried marijuana leaves wrapped in cellophane and newspaper in the bicycle’s basket. The forensic chemist confirmed the substance was marijuana. Appellant was arrested and the items were confiscated.
Appellant denied the charge, claiming he was merely asked by a certain Boyet Obias to deliver a package, which he believed contained cookies, to another person. He testified he was unaware the package contained marijuana. The defense presented a corroborating witness. The trial court convicted appellant of transporting a prohibited drug and sentenced him to reclusion perpetua and a fine of One Million Pesos. The Court of Appeals affirmed the conviction in toto.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction for violation of Section 4, Article II of R.A. No. 6425, as amended.

RULING

The Supreme Court affirmed the conviction. The Court held that all elements of illegal transportation of dangerous drugs were proven beyond reasonable doubt: (1) the appellant transported or carried the marijuana; (2) he did so without legal authority. The finding of the marijuana in the basket of the bicycle he was riding constituted direct evidence of the act of transportation. His defense of lack of knowledge of the package’s contents was correctly rejected. Ignorance or lack of knowledge is not a valid defense in crimes that are mala prohibita, where the mere commission of the act constitutes the offense. The law does not require proof of criminal intent; good faith or absence of criminal intent is immaterial.
The Court found no merit in appellant’s challenge to the chain of custody of the seized marijuana. The testimonies of the apprehending officers and the forensic chemist established an unbroken chain from seizure to laboratory examination. Minor inconsistencies in their testimonies regarding the date the specimen was received by the chemist did not create reasonable doubt, as they pertained to collateral matters and did not undermine the integrity of the evidence. The penalty of reclusion perpetua and a fine of One Million Pesos was correctly imposed pursuant to the amendatory provisions of R.A. No. 7659.