G.R. No. 219590, June 7, 2017
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. MARCIAL M. PARDILLO, Accused-Appellant

FACTS

On February 2, 2007, police officers on patrol in Cebu City observed accused-appellant Marcial Pardillo holding two transparent plastic sachets in an alley. SPO1 Metodio Aparis, suspecting the sachets contained dangerous drugs, identified himself as a police officer and inquired about them. Pardillo responded that somebody had just asked him to buy shabu. The officers arrested him, confiscated the sachets, and brought him to the police station where the items were marked. Forensic examination confirmed the sachets contained methamphetamine hydrochloride. Pardillo was charged with illegal possession of dangerous drugs under Section 11 of Republic Act No. 9165.
The accused-appellant presented a different version, claiming he was merely standing outside his house when accosted and frisked by a man who later identified himself as a police officer. He denied any knowledge of the drugs and asserted he was brought to the station and questioned about an unknown person named Edwin. The Regional Trial Court convicted him, a decision affirmed by the Court of Appeals, leading to this final appeal.

ISSUE

The core issues are: (1) whether the warrantless arrest and seizure were valid, and (2) whether the chain of custody over the seized drugs was properly established.

RULING

The Supreme Court affirmed the conviction, ruling both the warrantless arrest and the chain of custody were valid. On the first issue, the arrest fell under the exception in Section 5(a), Rule 113 of the Rules of Court for arrests without a warrant when a person is caught in flagrante delicto. The elements were present: SPO1 Aparis personally witnessed Pardillo’s overt act of holding the transparent sachets containing a suspicious white substance in an area known for drug trafficking, and Pardillo’s immediate reply that he was asked to buy shabu upon police inquiry confirmed the officer’s reasonable suspicion that a crime was being committed. His claim of merely walking was rejected.
On the second issue, the Court held that while the ideal chain of custody under Section 21 of RA 9165 requires strict procedural steps, substantial compliance is sufficient provided the integrity and evidentiary value of the seized items are preserved. The marking of the sachets at the police station and their subsequent forensic examination established an unbroken chain. Any minor procedural lapse was not fatal. The trial court’s factual findings, affirmed by the CA, are accorded great weight, and the police officers are presumed to have performed their duties regularly in the absence of proof to the contrary. Thus, the guilt of the accused-appellant for illegal possession of dangerous drugs was proven beyond reasonable doubt.