Primary Holding

The Supreme Court acquitted Roel Gementiza Padillo because the prosecution failed to establish the validity of the search warrant's issuance and implementation, violating his constitutional rights, and failed to prove the integrity of the chain of custody of the seized items beyond a reasonable doubt.

Background

The Philippine Drug Enforcement Agency (PDEA) suspected Roel Padillo of possessing shabu at his residence in Balingoan, Misamis Oriental, prompting them to apply for and obtain a search warrant to search the premises.

Facts

• 1. PDEA-Region 10 agents planned and executed a search operation based on Search Warrant No. SW-208-2018 at Padillo's residence early morning on March 24, 2018.
• 2. The team arrived around 1:20 AM, called out to Padillo without response, entered through an unlocked gate, and used a battering ram to open the main door.
• 3. Padillo and his family were secured, and mandatory witnesses (barangay officials and a media representative) were summoned and arrived.
• 4. The search warrant was read to Padillo in the presence of the witnesses.
• 5. A search of the living room and kitchen yielded nothing.
• 6. During the search of Padillo's bedroom, witnessed by him and the mandatory witnesses, IO2 Tacal allegedly discovered 14 sachets of suspected shabu in a plastic drawer.
• 7. Padillo was arrested, informed of his rights, and handcuffed.
• 8. The seized items were marked and inventoried by IO2 Tacal on the dining table in the presence of Padillo and the witnesses, who signed the relevant documents (Receipt of Property Seized, Certification of Good Conduct Search).
• 9. Photographs were taken during the process.
• 10. The team returned to the PDEA office, filed a return of the warrant, and IO2 Tacal delivered the seized items to Forensic Chemist Ibale later that day (March 24, 2018).
• 11. Chemist Ibale confirmed the items tested positive for methamphetamine hydrochloride (total weight 51.7805 grams).
• 12. Ibale secured the items overnight and turned them over to Evidence Custodian Charlotte Roxas on March 25, 2018.
• 13. The items remained in the evidence room, secured by three locks, until Ibale retrieved them for court presentation on November 14, 2018.
• 14. Padillo and his witnesses claimed they were awakened by PDEA's forceful entry, moved from their room, and denied ownership of the drugs allegedly found in their bedroom drawer.

Arguments of the Petitioners

• 1. The implementation of the search warrant violated his constitutional right against unreasonable searches and seizures because PDEA officers forcibly entered his house without complying with the witness requirement under Rule 126, Section 8 of the Revised Rules of Criminal Procedure.
• 2. The prosecution failed to establish the chain of custody beyond a reasonable doubt, specifically pointing to the non-presentation of Evidence Custodian Roxas who possessed the seized specimens for nearly eight months, creating a crucial gap.

Arguments of the Respondents

• 1. The prosecution successfully proved all elements of the crime through the evidence presented.
• 2. The chain of custody of the seized drugs was properly established and complied with legal requirements.
• 3. The non-presentation of Evidence Custodian Roxas was inconsequential as the chain of custody was shown to be unbroken and the drugs were properly identified.
• 4. The absence of mandatory witnesses during the pre-operation briefing did not invalidate the operation as it is not required by law and briefings involve confidential matters.
• 5. Padillo waived any objections to the legality of the search warrant by failing to file a timely motion to quash or suppress evidence.

Issues

• 1. Whether the search warrant issued and implemented against Padillo was valid.
• 2. Whether the integrity of the chain of custody of the seized drugs was duly established by the prosecution.
• 3. Whether Padillo's guilt for violation of Section 11 of Republic Act No. 9165 was proven beyond a reasonable doubt.

Ruling

• 1. The Supreme Court found the search warrant invalid due to the prosecution's failure to present any evidence showing that the issuing judge conducted the required personal, searching examination of the applicant and witnesses to establish probable cause.
• 2. The Court also noted the lack of record justifying the warrant's nighttime implementation, violating Rule 126, Section 9, Rules of Criminal Procedure.
• 3. The Court ruled that the presumption of regularity cannot override the accused's fundamental constitutional rights, particularly the right against unreasonable searches and seizures.
• 4. Following the Abiang v. People ruling, the Court held that Padillo's failure to timely object to the warrant did not constitute a waiver, as procedural rules must yield to the protection of constitutional rights in cases of blatant violations.
• 5. Consequently, the evidence seized pursuant to the void search warrant was deemed inadmissible under the Exclusionary Rule (Art. III, Sec. 3(2), Constitution).
• 6. Independently, the Court found a substantial break in the fourth link of the chain of custody due to the unexplained eight-month period the drugs were held by the evidence custodian (Roxas) without her testimony or that of others with access.
• 7. The lack of testimony covering this crucial period and the absence of a chain of custody form severely undermined the integrity of the drug evidence.
• 8. Due to the inadmissibility of the primary evidence and the failure to establish an unbroken chain of custody, the prosecution failed to prove Padillo's guilt beyond a reasonable doubt, warranting his acquittal.

Doctrines

• 1. Right Against Unreasonable Searches and Seizures (Art. III, Sec. 2, Constitution): Protects individuals from arbitrary state intrusion, requiring valid warrants based on probable cause determined personally by a judge after examination.
• 2. Requirements for Valid Search Warrant Issuance: Mandates judicial determination of probable cause through personal examination under oath of complainant and witnesses, and particular description of place/things. Lack of proof of examination is fatal.
• 3. Nighttime Search Rule (Rule 126, Sec. 9, Rules of Criminal Procedure): Requires justification in the affidavit and explicit judicial direction for a warrant to be served at night.
• 4. Presumption of Regularity: Official acts are presumed regular, but this presumption cannot defeat constitutional safeguards protecting the accused.
• 5. Waiver of Objections to Search Warrant Illegality (Rule 126, Sec. 14, Rules of Criminal Procedure): Failure to file a timely motion to quash/suppress generally constitutes waiver, but this rule can be relaxed for blatant constitutional violations (Abiang doctrine).
• 6. Exclusionary Rule (Art. III, Sec. 3(2), Constitution): Evidence obtained through unconstitutional searches or seizures is inadmissible ("fruit of the poisonous tree").
• 7. Chain of Custody Doctrine: Requires the prosecution to establish the continuous, unbroken possession and integrity of seized illegal drugs through four specific links (seizure/marking, turnover to IO, turnover to chemist, turnover to court).
• 8. Proof Beyond Reasonable Doubt: The standard of proof required in criminal cases for conviction, demanding moral certainty.
• 9. Appeal Opens Whole Case for Review: An appeal in a criminal case allows the appellate court to examine all aspects, even those not specifically raised by the appellant.

Key Excerpts

• 1. "The absence of this critical judicial inquiry undermines the very foundation of the search warrant's validity."
• 2. "It is well settled that the presumption of regularity cannot prevail against the constitutional rights of the accused."
• 3. "The Court emphasized that the protection of constitutional rights must take precedence over procedural technicalities." (referring to relaxation of waiver rule)
• 4. "Without a clear and unbroken chain of custody, the integrity of the evidence is compromised, casting doubt on its integrity."

Precedents Cited

• 1. People v. Ramos (2017): Cited for the rule that an appeal in a criminal case opens the entire case for review.
• 2. People v. Gabiosa (2020): Cited regarding the fundamental nature of the right against unreasonable searches and seizures.
• 3. People v. Castillo (2016): Cited for the established requirements for a valid search warrant.
• 4. Zafe III v. People (2021) & People v. Mendoza (2014): Cited for the principle that the presumption of regularity yields to constitutional rights.
• 5. Abiang v. People (2023): Central case relied upon for relaxing the rule on waiver of objections to illegal searches when constitutional rights are blatantly violated.
• 6. Ogayon v. People (2015): Cited in relation to the Abiang doctrine concerning the non-waiver of fundamental rights.
• 7. People v. Mariano (2022): Cited for the enumeration of the four links required in the chain of custody for drug cases.

Statutory and Constitutional Provisions

• 1. Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002): Section 11 (Illegal Possession), Section 35 (Accessory Penalties).
• 2. 1987 Constitution: Article III, Section 2 (Right against unreasonable searches and seizures), Article III, Section 3(2) (Exclusionary Rule).
• 3. Revised Rules of Criminal Procedure: Rule 126, Section 8 (Witness requirement for forcible entry), Rule 126, Section 9 (Time of service of warrant), Rule 126, Section 14 (Motion to quash/suppress evidence).
• 4. Revised Penal Code: Article 29 (Credit for preventive imprisonment).