[ G.R. No. 217097.

February 23, 2022 ]

ROLANDO UY Y SAYAN ALIAS "NONOY," PETITIONER, VS. PEOPLE OF THE PHILIPPINES,
RESPONDENT.
Facts: This case involves a petition for review on certiorari challenging the decision of the Court of
Appeals (CA) that affirmed the Regional Trial Court's (RTC) ruling, finding the petitioner guilty of
violating Section 11, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
The petitioner was charged with illegal possession of 248 grams of marijuana and was found positive for
marijuana use. The prosecution presented evidence of a routine inspection at a checkpoint where
bundles of marijuana were discovered in the petitioner's motorcycle, and the petitioner's urine test
yielded positive for drug use. However, the defense presented a different version, alleging an unlawful
search and coercion by the police. The RTC found the petitioner guilty of Illegal Possession of
Dangerous Drugs, giving full faith and credit to the testimonies of the apprehending team regarding the
checkpoint operation, unless there is clear evidence of improper motive or negligence. Aggrieved,
petitioner appealed to the CA. The Court of Appeals upheld the RTC's decision but revised the penalty
due to the insufficiency of the urine evidence as standalone proof against the petitioner.

Issue: Whether the Court of Appeals erred in finding the petitioner guilty beyond reasonable doubt for
Illegal Possession of Dangerous Drugs under Section 11 of RA 9165.

Held: Yes. The SC held that the warrantless arrest and search in this case were valid since in this case,
the petitioner was flagged down at a checkpoint for failing to produce the required documents for his
motorcycle, which raised suspicions. The subsequent search led to the discovery of marijuana. The
arrest and search were not directly related to the COMELEC gun ban or a traffic violation but were
based on the petitioner's failure to present documents and the suspicions raised by the officers.
However, the court found that the police officers failed to comply with the rule on the chain of
custody, violating Section 21 of RA 9165. The absence of an inventory report and the required presence
of witnesses during the seizure of the drugs created uncertainty regarding the identity and integrity of
the evidence. As a result, the court concluded that the petitioner should be acquitted.

FULL TEXT: https://lawphil.net/judjuris/juri2022/feb2022/gr_217097_2022.html