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People vs. Eyam

The appeal was dismissed, the Court of Appeals' decision affirming the Regional Trial Court's conviction of George Eyam y Watang for illegal possession of dangerous drugs having been sustained. Appellant was found in possession of shabu without authorization, establishing the crime under Section 11, Article II of Republic Act No. 9165. Mere possession of the dangerous drug constituted prima facie evidence of knowledge, which appellant failed to overcome.

Primary Holding

Mere possession of a dangerous drug constitutes prima facie evidence of knowledge, shifting the burden to the possessor to rebut the presumption, provided the prosecution first establishes the fact of unauthorized possession.

Background

George Eyam y Watang was charged with illegal possession of methylamphetamine hydrochloride (shabu) in an Information filed on July 17, 2003. He was apprehended and found in possession of the dangerous drug without legal authority.

History

  1. Information filed in RTC charging appellant with illegal possession of dangerous drugs (July 17, 2003)

  2. RTC convicted appellant (March 8, 2006)

  3. CA affirmed RTC conviction (September 20, 2007)

  4. Appeal dismissed and CA Decision affirmed by the Supreme Court (November 26, 2012)

Facts

  • The Charge: Appellant was charged with illegal possession of methylamphetamine hydrochloride (shabu) under an Information filed on July 17, 2003.
  • The Possession: Appellant was caught in possession of shabu, a dangerous drug, without authorization.

Ruling

  • Prima Facie Evidence of Knowledge: The conviction was sustained because the prosecution established that appellant was caught in unauthorized possession of shabu, and mere possession constitutes prima facie evidence of knowledge which appellant failed to rebut.

Doctrines

  • Prima Facie Evidence of Knowledge in Drug Possession — Mere possession of a dangerous drug constitutes prima facie evidence of knowledge of the possession. The burden shifts to the accused to rebut this presumption. The Court applied this to affirm the conviction, as appellant failed to rebut the presumption after the prosecution established the fact of unauthorized possession.

Provisions

  • Section 11, Article II, Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) — Cited as the provision under which the appellant was charged and convicted for illegal possession of dangerous drugs.

Notable Concurring Opinions

Antonio T. Carpio (Chairperson), Arturo D. Brion, Jose Portugal Perez, Jose Catral Mendoza.