G.R. No. 203984, June 18, 2014
People of the Philippines, Plaintiff-Appellee, vs. Medario Calantiao y Dimalanta, Accused-Appellant.

FACTS

On November 11, 2003, in Caloocan City, accused-appellant Medario Calantiao was charged with illegal possession of 997.9 grams of marijuana fruiting tops in violation of Section 11, Article II of Republic Act No. 9165. The prosecution evidence established that on November 13, 2003, a civilian, Edwin Lojera, reported a shooting incident to the police, stating that after a traffic dispute, the passengers of a white taxi, one of whom was Calantiao, alighted and fired guns at him. Police officers PO1 Nelson Mariano and PO3 Eduardo Ramirez responded, located the taxi, and were fired upon by two armed men who alighted and fled. The officers chased and subdued them. PO1 Mariano recovered from Calantiao a black bag containing two bricks of dried marijuana fruiting tops and a magazine. The items were turned over to the investigator, marked, and forwarded to the PNP Crime Laboratory, where they tested positive for marijuana. The defense presented a different version, claiming the incident stemmed from a traffic mishap where Calantiao’s companion made an offensive gesture, leading to an altercation with PO1 Mariano, who then framed them by planting the marijuana.

ISSUE

Whether the Court of Appeals erred in affirming the Regional Trial Court’s decision convicting accused-appellant of illegal possession of dangerous drugs, despite questions regarding the admissibility of the seized items due to an alleged illegal search and a broken chain of custody.

RULING

The Supreme Court affirmed the conviction. The warrantless arrest was lawful as the accused was caught in flagrante delicto firing at the police officers. The subsequent search and seizure of the marijuana from the black bag he was carrying were valid as a search incident to a lawful arrest, permissible to remove weapons or prevent the destruction of evidence within the arrestee’s immediate control. The Court found that the prosecution established all elements of illegal possession. The defense of denial and frame-up was not proven by clear and convincing evidence. The chain of custody was not broken; the procedural requirements under Section 21 of RA 9165 are not absolute, and non-compliance does not automatically render the seizure invalid absent proof of bad faith. The integrity and evidentiary value of the seized drugs were preserved.