G.R. No. L-11772; August 31, 1916
THE UNITED STATES, plaintiff-appellee, vs. GAN LIAN PO, defendant-appellant.

FACTS:
On February 29, 1916, police officers raided a building at No. 317 Ilang-Ilang Street, Manila, owned by Gan Lian Po, who operated a sack manufacturing business there. The superintendent and manager of the business was Ko Seng. During the raid, the officers discovered and seized 206 grams and 15 centigrams of cocaine and 2 kilograms and 889 grams of morphine hidden among sacks in a room. An information was filed charging Gan Lian Po and six others, including Ko Seng, with illegal possession of prohibited drugs. At the close of the prosecution’s case, five accused were acquitted. Ko Seng pleaded guilty. Gan Lian Po pleaded not guilty, was convicted, and sentenced to one year’s imprisonment, a P2,000 fine, and a share of the costs. The central factual dispute was whether Gan Lian Po had knowledge of the drugs’ presence on his premises. The prosecution relied primarily on the legal presumption arising from the discovery of the drugs in his building and on the testimony of Police Sergeant J.J. Sullivan, who claimed Gan Lian Po admitted knowing the drugs were hidden there. Gan Lian Po denied any prior knowledge, testifying that Ko Seng managed the business day-to-day, that he had many employees, and that he only learned of the drugs from Ko Seng during the raid itself.

ISSUE:
Did the prosecution prove beyond a reasonable doubt that Gan Lian Po had knowledge of the presence of the prohibited drugs on his premises prior to the police raid, thereby making him criminally liable for illegal possession?

RULING:
No. The Supreme Court reversed the conviction and acquitted Gan Lian Po. The Court acknowledged the legal presumption that the owner or occupant of premises where prohibited drugs are found is in possession thereof. However, this presumption is rebuttable. The Court found that Gan Lian Po successfully rebutted the presumption. The testimony of Sergeant Sullivan was deemed unreliable due to likely misunderstandings arising from language barriers (the conversation was in broken Spanish/English between a non-native speaker and an officer who did not speak Chinese). The appellant’s statement, “Si, señor, mi sabe morphine,” was ambiguous and did not conclusively prove prior knowledge of the drugs’ specific location. Considering the appellant’s denial, his explanation that the business was under Ko Seng’s control, the opportunity for concealment by employees, and the lack of other cogent evidence, the Court held that the prosecution failed to prove guilt beyond a reasonable doubt. The evidence as a whole created a reasonable doubt as to whether the appellant had knowledge of the drugs’ presence before the raid.