G.R. No. 199898, September 3, 2014
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. LEO DELA TRINIDAD y OBALLES, Accused-Appellant.

FACTS

On October 22, 2008, an Information was filed accusing Leo Dela Trinidad y Oballes of violating Section 11, Article II of R.A. No. 9165 (Comprehensive Dangerous Drugs Act of 2002) for possessing, without authority, various quantities of suspected marijuana with a total weight of approximately 1,121.5 grams. The prosecution’s version established that the Naga City Police Intelligence Section received information on September 27, 2008, about appellant’s alleged drug trafficking. Surveillance and two test-buys (on October 10 and 16, 2008) confirmed the report, with an asset purchasing marijuana from appellant. Based on this, the police applied for and obtained two search warrants (one for drugs, one for a firearm reportedly seen). After coordination with the PDEA and a briefing attended by mandatory witnesses (DOJ representative, media representative, and barangay officials), the team executed the warrants at appellant’s residence around 5:10 AM on October 21, 2008. The police identified themselves, read the warrants, and informed appellant of his rights. Appellant voluntarily presented items from under his pillow, which included bricks and cubes of suspected marijuana and empty plastic sachets. An inventory was conducted and signed by witnesses in appellant’s presence. The seized items were marked, brought to the police station, and subsequently submitted to the crime laboratory, where they tested positive for marijuana. The defense claimed the items were planted, stating that upon opening the door for people claiming to be “Kapitan,” the operatives entered, took pictures, and later claimed to have found the drugs while appellant was seated with his hands on his nape. He was then made to sign a paper, handcuffed, and arrested.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s conviction of the accused-appellant for violation of Section 11, Article II of R.A. No. 9165, despite the alleged failure of the prosecution to prove his guilt beyond reasonable doubt.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the decision of the Court of Appeals. The Court found that all elements of illegal possession of dangerous drugs were proven beyond reasonable doubt: (1) the accused was in possession of an item identified as a prohibited drug; (2) such possession was not authorized by law; and (3) the accused freely and consciously possessed the drug. The Court upheld the findings of the lower courts that the police operatives complied with the chain of custody requirements under Section 21 of R.A. No. 9165. The marking, physical inventory, and photographing of the seized items were done in the presence of the accused and the required witnesses (representatives from the DOJ, media, and elected barangay officials). The integrity and evidentiary value of the seized drugs were thus preserved. The defense of denial and frame-up was deemed unconvincing and unsupported by clear and convincing evidence, especially since appellant did not present his alleged witness (his wife) to corroborate his claim. The testimonies of the prosecution witnesses were given full faith and credit, and the police operatives enjoyed the presumption of regularity in the performance of their duties in the absence of proof to the contrary. The penalty imposed by the Regional Trial Court—life imprisonment and a fine of Two Million Pesos (₱2,000,000.00)—was affirmed.