G.R. No. L-8995; November 6, 1913
THE UNITED STATES, plaintiff-appellee, vs. CHUA LUI, defendant-appellant.

FACTS:
Chua Lui leased and occupied a house in Caloocan. On March 25, 1913, police officers went to the house. Upon their approach, Koh Kieng Sien, a visitor, jumped from a window and fled. The officers chased, arrested him, and recovered a bamboo container he had discarded, which held an opium pipe and a can of opium. The officers then arrested Chua Lui and the other occupants of the house (Chua Tong and Chua Bee Cho). All were charged with illegal possession of opium under Act No. 1761 , as amended. A thorough search of the house revealed no opium or related paraphernalia. The prosecution’s case against Chua Lui rested entirely on the opium found in Koh Kieng Sien’s possession. The evidence showed that Koh Kieng Sien was a casual visitor, present only for a few hours to borrow money from Chua Lui to pay a fine from a prior opium conviction. All accused, except Koh Kieng Sien, denied any knowledge or possession of opium. The trial court convicted Chua Lui and Koh Kieng Sien. Only Chua Lui appealed.

ISSUE:
Whether Chua Lui can be held criminally liable for the illegal possession of opium based solely on the fact that a temporary visitor (Koh Kieng Sien) was found in possession of opium on the premises leased by Chua Lui.

RULING:
No. The Supreme Court reversed the conviction and acquitted Chua Lui. The Court held that the mere presence of a temporary visitor in possession of opium on one’s premises is insufficient to prove, beyond a reasonable doubt, that the owner or occupant had knowledge, possession, or control of the contraband. Citing United States vs. De los Reyes, the Court ruled that the act of a visitor in bringing and attempting to dispose of opium does not, without more, impute knowledge or criminal liability to the occupant. Furthermore, citing United States vs. Tan Tayco, the Court emphasized that legal possession requires both physical control (corpus) and the intent to possess (animus possidendi). No evidence was presented to show that Chua Lui had any connection to the opium, intended to possess it, or that the house was used as an opium den. The prosecution failed to prove Chua Lui’s guilt beyond a reasonable doubt.