View full case

PEOPLE v. CARLOS DELA CRUZ

FACTS:

This case is an appeal from the decision of the Court of Appeals (CA) which affirmed the decision of the Regional Trial Court (RTC) finding the accused guilty of violation of the Comprehensive Dangerous Drugs Act of 2002. The accused was charged with illegal possession of firearm and ammunition, as well as possession of dangerous drugs. According to the prosecution, the accused was seen holding a shotgun during a shootout with the police, and upon his arrest, a plastic bag of suspected shabu was found in his possession. The defense, on the other hand, claimed that the accused was at the house of another person doing welding work at the time of the incident, and denied the allegations against him. The RTC acquitted the accused of illegal possession of firearm and ammunition, but convicted him of possession of dangerous drugs. The accused appealed, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, and that his arrest was illegal. The CA upheld the conviction, stating that the accused was positively identified and that his allegations of a frame-up and illegal arrest were not substantiated. The accused now presents several issues before the Supreme Court, including the failure of the prosecution to prove constructive possession of the drugs.

ISSUES:

  1. Whether the version of the prosecution should have been given full credence.

  2. Whether the prosecution proved beyond reasonable doubt that accused-appellant was guilty of possession of an illegal drug.

  3. Whether accused-appellant's arrest was illegal.

  4. Whether the prosecution established the chain of custody of the illegal drug allegedly found in accused-appellant's possession.

RULING:

  1. The Court finds no error in the trial court's decision to give full credence to the version of the prosecution. The positive identification of accused-appellant by prosecution witnesses strengthens their testimony and weakens accused-appellant's mere denial and allegation of frame-up.

  2. The prosecution has indeed proven accused-appellant's guilt beyond reasonable doubt for the offense of possession of dangerous drugs. Both actual and constructive possession were sufficiently established, as accused-appellant was found in close proximity to the drugs and their presence was proven through the testimonies and physical evidence presented.

  3. Accused-appellant's claim of an illegal arrest is deemed waived since he failed to challenge it during his plea, application for bail, and active participation in the trial. Moreover, the arrest was validly conducted as it was made pursuant to a lawful warrant of arrest.

  4. The prosecution successfully established the chain of custody of the illegal drug. Accused-appellant's claim of tampering or meddling without supporting evidence is unpersuasive.

PRINCIPLES:

  • The positive identification of the accused by prosecution witnesses strengthens their testimonies and weakens the defense's denial and allegation of frame-up.

  • Both actual and constructive possession can be proven beyond reasonable doubt for the offense of possession of dangerous drugs.

  • Failure to challenge an alleged illegal arrest during plea, application for bail, and active participation in the trial may be considered as a waiver of the right to question such arrest.

  • The prosecution has the burden to establish the chain of custody of seized drugs, but unsupported claims of tampering or meddling are unpersuasive.