People v. Delos Santos
REITERATIONFacts
The Antecedents: Geron Delos Santos y Maristela was apprehended by a security guard at the Somerset Condominium for attempting to bring out a gift-wrapped box. Upon inspection, the box was found to contain 6.2 kilograms of suspected shabu. Delos Santos was immediately apprehended, and the box and its contents were impounded. The National Bureau of Investigation (NBI) was notified. Procedural History: Delos Santos was charged with violation of Section 16 of Republic Act No. 6425 (Dangerous Drugs Act of 1972). He pleaded not guilty. The Regional Trial Court (RTC) convicted him, sentencing him to suffer reclusion perpetua and to pay a fine of P500,000.00. The Court of Appeals (CA) affirmed the RTC decision. Delos Santos appealed to the Supreme Court. The Petition: Delos Santos appealed to the Supreme Court, contending that the trial court erred in considering the evidence against him as hearsay and in convicting him despite the fact that he did not knowingly possess the prohibited drugs.
Issue(s)
Whether the testimonies of NBI agent Esmeralda and building security supervisor Zabat were hearsay. Whether the State established animus possidendi (intent to possess) on the part of the accused. Whether the accused knowingly possessed the prohibited drugs.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, finding Geron Delos Santos y Maristela guilty beyond reasonable doubt of the violation of Section 16 of Republic Act No. 6425, as amended by Republic Act No. 7659.
Ratio Decidendi
On the issue of hearsay evidence: The Court ruled that Delos Santos waived his objection to the testimonies of NBI agent Esmeralda and building security supervisor Zabat by failing to raise it during the trial. Furthermore, his express admission of actual possession of the box containing the shabu rendered the testimony of the apprehending security guard unnecessary. The testimonies of Esmeralda and Zabat were not hearsay regarding his possession, as they were eyewitnesses to the physical turn-over of the seized shabu, directly linking Delos Santos to the evidence. On the issue of animus possidendi: The Court held that proof of animus possidendi is indispensable in prosecutions for possession of illegal substances. This state of mind is determined by considering the prior and contemporaneous acts of the accused and the surrounding circumstances. The Court found that Delos Santos' conduct prior to and following his apprehension evinced guilty knowledge of the contents of the box. His explanation of being summoned to clean Unit 706 was a sham, especially since he was no longer employed as a janitor. His willingness to deliver the box for Wilson indicated he was acting as a courier of shabu. His unreasonable refusal to exit Unit 706 and his stealthy transfer to Unit 705 further confirmed his guilty knowledge and attempt to escape. On the issue of knowing possession: The Court concluded that Delos Santos possessed animus possidendi, which inherently implies knowing possession. His actions demonstrated a clear intent to possess the illegal drugs. The presumption of animus possidendi arose because he performed an act that the law prohibited and punished, and he failed to provide a satisfactory explanation for his possession of the box containing the shabu. His mere denial of knowledge was insufficient to overcome this presumption.
Main Doctrine
The mere denial of knowledge that a substance is a regulated drug is insufficient to exculpate the person found in possession of it; the person must satisfactorily explain how the drug came into their possession. Without such explanation, the presumption of animus possidendi (intent to possess) arises, establishing guilt beyond reasonable doubt.