G.R. No. 190623 November 17, 2014
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ROMMEL ARAZA y SAGUN, Accused-Appellant.

FACTS

An Information was filed against Rommel Araza y Sagun (Araza) for illegal possession of shabu in violation of Section 11, Article II of Republic Act No. 9165 . The prosecution presented PO1 Edmund Talacca, who testified that on August 28, 2002, at around 8:00 p.m., while confiscating a video karera machine in the house of Alejandro Sacdo, he saw nine persons, including Araza, sniffing shabu. Araza was arrested and frisked, and a small heat-sealed transparent plastic sachet containing white crystalline substance was recovered from his pocket. PO1 Talacca seized the sachet, brought Araza to the police station, and turned over the sachet to investigator Larry Cabrera, who marked it with “RSA” in PO1 Talacca’s presence. The defense stipulated to the Chemistry Report (Exhibit B) confirming the substance was methamphetamine hydrochloride. Araza testified that he was sleeping when PO1 Talacca woke him up, frisked him, confiscated his wallet, and brought him to the police station. The Regional Trial Court found Araza guilty beyond reasonable doubt, sentencing him to imprisonment and a fine. The Court of Appeals affirmed the RTC Decision. Araza appealed, arguing the warrantless arrest was invalid and the chain of custody procedure was not complied with.

ISSUE

Whether the Court of Appeals erred in upholding the validity of Araza’s warrantless arrest and in finding that the procedure for the custody and control of prohibited drugs was complied with.

RULING

The Supreme Court dismissed the appeal and affirmed the Court of Appeals Decision. On the first issue, the Court ruled that Araza is estopped from assailing the legality of his arrest after his arraignment without prior objection. On the second issue, the Court held that the prosecution established all elements of illegal possession of dangerous drugs: (1) Araza possessed an item identified as a prohibited drug; (2) such possession was not authorized by law; and (3) he freely and consciously possessed it. The testimony of PO1 Talacca was credible and buttressed by the presumption of regularity in the performance of official duties. The chain of custody was sufficiently established through PO1 Talacca’s testimony about the seizure, marking, and turnover of the sachet, and the stipulations regarding the forensic examination. The penalty imposed by the RTC, as affirmed by the CA, was within the range provided by law.