People v. David
NEW DOCTRINEFacts
1. The Antecedents: The case originated from an information received by the Concepcion Police Station regarding the sale of illegal drugs at L. Cortez St., Brgy. San Jose, Concepcion, Tarlac. Following surveillance, a search warrant was obtained. During the implementation of the warrant on June 29, 2003, police operatives found six (6) sachets of marijuana and three (3) plastic sachets of suspected shabu on top of a padlocked cabinet. The seized items were later confirmed by laboratory examination to be 3.865 grams of marijuana and 0.327 grams of shabu. Consequently, the petitioner, Raul David, was charged with illegal possession of these dangerous drugs under two separate Informations. 2. Procedural History: The petitioner pleaded not guilty to both charges. After trial, the Regional Trial Court (RTC), Branch 66, Capas, Tarlac, found him guilty beyond reasonable doubt for violation of Section 11, Article II of Republic Act No. 9165, sentencing him to an indeterminate penalty. The petitioner appealed this decision to the Court of Appeals (CA). The CA affirmed the conviction but modified the sentence, imposing separate penalties for each offense. The petitioner's subsequent Motion for Reconsideration was denied by the CA. 3. The Petition: The petitioner filed a Petition for Review on Certiorari under Rule 45 of the 1997 Rules of Civil Procedure, assailing the CA's decision and resolution. He raised issues concerning the credibility of prosecution witnesses, the failure to prove the identity of the seized drugs, and the conviction for two separate offenses when the drugs were allegedly found on a single occasion. The petitioner argued that the CA erred in affirming his conviction and that the assailed decision was not in accordance with law and jurisprudence, potentially causing grave injustice. The Supreme Court, however, found the petition to be without merit, noting that the arguments were primarily factual and that the lower courts' findings were supported by evidence. The Court also addressed the issue of whether possession of different dangerous drugs in one instance constitutes a single offense, ultimately ruling in favor of the petitioner on this point, but affirming the conviction.
Issue(s)
Whether the Court of Appeals erred in giving credence to the testimonies of the prosecution witnesses. Whether the Court of Appeals erred in convicting the petitioner despite the failure of the prosecution to prove that the dangerous drugs submitted for laboratory examination and presented as evidence before the trial court were the same ones allegedly seized. Whether the Court of Appeals erred in modifying the decision of the trial court which found the petitioner guilty of a single charge of violation of Section 11, Article II of Republic Act No. 9165.
Ruling
The petition is denied. The decision of the Court of Appeals is affirmed with the modification that the penalty of imprisonment for twelve (12) years and one (1) day, as minimum, to fourteen (14) years, as maximum, and a fine of Three Hundred Thousand Pesos (₱300,000.00) shall be imposed, reflecting a single offense of possession of dangerous drugs.
Ratio Decidendi
On the credibility of prosecution witnesses: The Court held that the testimonies of police officers are generally given credence, absent evidence of motive to falsely impute a crime. Any inconsistencies regarding the surveillance were deemed minor and did not detract from the fact that surveillance was conducted. The Court reiterated that the presumption of regularity in the performance of official duty prevails over self-serving denials. The findings of the RTC, affirmed by the CA, are conclusive. On the identity and integrity of the seized drugs: The Court found that the prosecution established an unbroken chain of custody. The seized items were marked, photographed in the presence of the barangay captain, and inventoried. Although strict compliance with Section 21 of R.A. 9165 was not fully met, the integrity and evidentiary value of the seized items were preserved, negating any possibility of substitution. The chemistry report confirmed the substances were dangerous drugs. On the conviction for a single offense: The Court found merit in the petitioner's contention that possessing different kinds of dangerous drugs on a single occasion should constitute only one offense under R.A. 9165. The Court noted that R.A. 9165 removed the distinction between prohibited and regulated drugs, classifying all as "dangerous drugs." Citing legislative intent and the principle of construing penal laws liberally in favor of the accused, the Court ruled that only one offense is committed, and the higher penalty should be imposed. The CA's modification of imposing separate penalties was thus corrected.
Main Doctrine
The possession of different kinds of dangerous drugs on a single occasion constitutes only one offense of illegal possession of dangerous drugs under R.A. 9165, and the higher penalty shall be imposed.