FACTS:

Appellant was charged with illegal possession of methylamphetamine hydrochloride or shabu in violation of Section 11, Article II of Republic Act No. 9165. Appellant pleaded not guilty to the charge. According to the prosecution, a security guard patted appellant's back pocket during a routine inspection and felt something bulky. Appellant brought out a plastic sachet containing shabu. He was apprehended and brought to the security office, where the sachet was marked. Appellant and the sachet were then brought to the police precinct for recording and investigation. The plastic sachet was eventually submitted to the Crime Laboratory for examination. On the other hand, the defense presented a different version of the incident. According to appellant, he was falsely implicated by the security guard after another man fled from being frisked. Appellant denied any knowledge of the man and claimed that he was frisked, beaten, and tortured by four men, including the security guard. Due to the beatings, he lost consciousness and admitted ownership of the shabu. He was then taken to the prosecutor's office for inquest. The trial court found appellant guilty beyond reasonable doubt, which was affirmed by the Court of Appeals. Appellant now raises issues regarding the failure of the prosecution to prove that the confiscated item was shabu and the chain of custody of the specimen. He also argues that the defense evidence is more credible than that of the prosecution.

ISSUES:

1. Whether the prosecution was able to establish that the item confiscated was a prohibited drug and establish the chain of custody of the specimen.

2. Whether the trial court failed to consider the evidence presented by the defense which is more credible than that of the prosecution.

RULING:

1. The Court cannot accept appellant's version of the events as it is contrary to the evidence presented by the prosecution. The credibility of the prosecution witnesses was affirmed by the trial court and the CA, and the court gives great weight and respect to their findings. Appellant's arguments that the prosecution failed to establish the nature of the confiscated item and the chain of custody were debunked by the court, as it found that the prosecution was able to establish the integrity and evidentiary value of the confiscated item. The court also ruled that the trial court did not gravely err in giving more weight to the prosecution's evidence over that of the defense. Thus, the conviction of appellant was upheld.

PRINCIPLES:

• The credibility of witnesses is generally a matter best addressed by the trial court, which has the advantage of observing the demeanor of witnesses while testifying. (People v. Micha, G.R. No. 231696, August 19, 2019)

• The prosecution has the burden of proving the guilt of the accused beyond reasonable doubt. To secure a conviction for illegal possession of dangerous drugs, the following elements must be proven: (a) the accused is in possession of the item or object identified as a prohibited drug; (b) such possession is not authorized by law; and (c) the accused freely and consciously possessed the said drug. (People v. Nuesca, G.R. No. 209135, October 3, 2016)

• The prosecution has the duty to prove the identity of the prohibited drug beyond reasonable doubt, as well as the fact that the same drug presented in court is the one actually seized from the accused. (People v. Miranda, G.R. No. 232358, June 5, 2019)