Primary Holding

The Supreme Court held that Lina Achieng Noah is guilty beyond reasonable doubt of illegally transporting dangerous drugs, affirming her conviction and life imprisonment sentence, as the prosecution successfully established an unbroken chain of custody for the seized shabu and proved all elements of the crime.

Background

Lina Achieng Noah was apprehended at Ninoy Aquino International Airport Terminal 1 upon arrival from Kenya via Dubai. Customs Examiner Landicho became suspicious of her luggage, leading to a further inspection in an exclusion room. This inspection revealed packages of shabu concealed within a laptop bag inside her luggage. Noah claimed the luggage was given to her and denied knowledge of the drugs.

Facts

• 1. On February 24, 2012, Lina Achieng Noah arrived at NAIA Terminal 1 from Kenya via Dubai.
• 2. Customs Examiner Marius Landicho asked to inspect her luggage, a black trolley bag and a laptop bag inside.
• 3. Landicho found the laptop bag suspiciously hard and padded.
• 4. Noah was brought to an exclusion room for further inspection.
• 5. In the exclusion room, in the presence of several witnesses, Landicho opened the laptop bag and discovered seven rectangular packages wrapped in aluminum foil.
• 6. The packages contained white crystalline substance which tested positive for methamphetamine hydrochloride (shabu).
• 7. Noah claimed she was in the Philippines for a job and the bag was given to her by an unidentified man in Cameroon.
• 8. Airline bag tags with Noah’s name were attached to the luggage.

Arguments of the Petitioners

• 1. The prosecution successfully proved the identity and integrity of the seized drugs through an unbroken chain of custody.
• 2. The chain of custody was properly documented, starting from the seizure at the airport to presentation in court.
• 3. Even if there was non-compliance with Section 21 of R.A. 9165, it was not fatal as the integrity and evidentiary value of the seized items were preserved.
• 4. The essential elements of illegal drug transportation were established: transportation of illegal drugs and the existence of the prohibited drug.

Arguments of the Respondents

• 1. The chain of custody of the evidence was broken, raising reasonable doubt about the authenticity of the seized shabu due to gaps in handling.
• 2. The marking of seized items was not immediately done upon seizure nor in her presence, affecting the integrity and evidentiary value.
• 3. Compliance with Section 21(a) of R.A. 9165's Implementing Rules and Regulations should not be relaxed because the prosecution failed to explain lapses in evidence handling.
• 4. She denied knowledge and ownership of the drugs, claiming the bag was given to her.

Issues

• 1. Whether or not the guilt of Lina Achieng Noah for violation of Section 5 of R.A. No. 9165 was proven beyond reasonable doubt.
• 2. Subsumed issue: Whether or not the prosecution established an unbroken chain of custody of the drug seized from Noah.

Ruling

• 1. The Supreme Court ruled in the affirmative on both issues, upholding Noah's conviction.
• 2. The Court found that the prosecution successfully established beyond reasonable doubt that Noah illegally transported dangerous drugs.
• 3. The chain of custody was proven to be unbroken through the testimonies of witnesses and documentary evidence, showing proper seizure, marking, handling, and presentation of the shabu.
• 4. The Court emphasized that the act of transporting illegal drugs is malum prohibitum, meaning intent is not essential, and proof of ownership is immaterial, focusing instead on the act of transportation and the integrity of the seized drugs.
• 5. Minor discrepancies in the procedural requirements of Section 21 are not fatal if the integrity and evidentiary value of the seized drugs are preserved, which was the case here.

Doctrines

• 1. Chain of Custody: The duly recorded authorized movements and custody of seized items at each stage, from seizure to presentation in court, ensuring the integrity and identity of the evidence. This is crucial in drug cases as the corpus delicti is not readily identifiable.
• 2. Corpus Delicti: The body of the crime; in drug cases, the seized illegal drug itself. Its integrity and identity must be proven beyond reasonable doubt.
• 3. Malum Prohibitum: An act that is wrong because it is prohibited by statute, not inherently wrong. Illegal transportation of drugs falls under this, meaning intent is not a necessary element for conviction, only the commission of the prohibited act.
• 4. Consented Search (Implied Consent in Airports): Searches conducted in airport premises are considered consented searches as part of security protocols.

Key Excerpts

• 1. "To sustain a conviction for the crime of illegal transportation of dangerous drugs, the transportation and the identity and integrity of the seized drugs must be proven beyond reasonable doubt."
• 2. "While testimony about a perfect chain is not always the standard because it is almost always impossible to obtain, an unbroken chain of custody becomes indispensable and essential when the item of real evidence is not distinctive and is not readily identifiable..."
• 3. "Accused-appellant exercised control and took possession of the luggage and its corresponding claim stub. It must be stressed that the act of transporting illegal drugs is a malum prohibitum. Consequently, proof of ownership and intent are not essential elements of the crime."

Precedents Cited

• 1. Mallillin v. People: Established the chain of custody rule as a method of authenticating evidence. Used to define and explain the necessity of chain of custody.
• 2. People v. Nandi: Outlined the four links in the chain of custody. Used to enumerate the necessary steps for establishing chain of custody.
• 3. People v. Dimaano and People v. Laba: Cited to emphasize the need to prove transportation and the identity/integrity of seized drugs for conviction.
• 4. People v. Guzon: Cited to reiterate that proof of ownership of drugs is immaterial. Also cited to support the necessity of proving transportation and integrity of seized drugs.
• 5. People v. Asislo: Cited regarding essential elements of illegal drug transportation.
• 6. People v. Watamama: Cited regarding essential elements of illegal drug transportation.
• 7. People v. Mariacos: Cited regarding corpus delicti in drug cases.
• 8. People v. Casacop: Cited regarding corpus delicti.
• 9. People v. Ismael and Fajardo v. People: Cited to show the importance of chain of custody for non-distinctive evidence.
• 10. People v. Que: Cited regarding compliance with Section 21 of R.A. 9165 and its effect on the integrity of corpus delicti.
• 11. People v. Del Mundo: Cited to show that proof of ownership is not essential in illegal drug transportation cases.

Statutory and Constitutional Provisions

• 1. Article II, Section 5 of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002): Defines and penalizes the illegal transportation of dangerous drugs.
• 2. Article II, Section 21 of Republic Act No. 9165 (as amended by R.A. No. 10640): Outlines the procedure for custody and disposition of seized drugs.
• 3. Dangerous Drugs Board Regulation No. 1, (2002), sec. 1(b): N/A (Cited generally, specific relevance not detailed in this digested portion).