Faithful observance of the rules provided under Section 21 of Republic Act (RA) No. 9165, otherwise known as the "Comprehensive Dangerous Drugs Act of 2002" is always desirable from our police authorities. Nevertheless, the evils sought to be avoided by these rules are obviated when the dangerous drugs recovered are of large quantities. Thus, while we still strongly encourage our police to strictly follow the rules on chain of custody, we will generally not prevent the arms of our law from reaching large-scale peddlers of dangerous drugs by the simple reason that departures from said rules were committed.

The Case

This Court resolves an appeal assailing the Decision^[1] dated 04 September 2015, of the Court of Appeals (CA) in CA-G.R. CR-HC No. 06171 which affirmed the Judgment^[2] dated 15 April 2013 rendered in Criminal Case No. 08-0517 of the Regional Trial Court, Branch 259, Parañaque City (RTC), finding Chih Chien Yang (Yang) guilty beyond reasonable doubt of Section 11, Article II of RA 9165, and sentencing him to suffer the penalty of life imprisonment and to pay a fine of P1,000,000.00.

Antecedents

In an Information dated 21 April 2008, Yang was charged of illegally possessing 9.9 kilograms of Ketamine Hydrochloride. The accusation reads:

That on or about the 19^th day of April, 2008 in the City of Parañaque, above-named accused, not being authorized by law to possess, did then and there willfully, unlawfully and feloniously have in his possession and under his control and custody Ketamine Hydrochloride weighing 9.9 Kilograms, a dangerous drug.

CONTRARY TO LAW.^[3]

When arraigned, Yang pleaded not guilty.^[4] Thus, trial on the merits followed, during which the prosecution offered the following version of the events that led to Yang's arrest:

At around 3:00 o'clock in the afternoon of 19 April 2008, a team composed of police operatives from the Anti-Illegal Drugs Special Operations Task Force (AIDSOTF) from Camp Crame, Quezon City, headed by Police Chief Inspector Rommel Ochave went to Yang's residence at No. 19-B Humility St., Multinational Village, Parañaque City, to implement a search warrant dated 18 April 2008 issued by Manila Executive Judge Reynaldo G. Ros of the RTC of Manila, Branch 33, for probable violation of Section 11 of R.A. No. 9165. The group was likewise armed with a warrant of arrest dated 21 May 2007 issued by Judge Catherine Manodon of the Metropolitan Trial Court of Quezon City, Branch 43, against Yang for probable violation of Article 172, in relation to Article 175 (paragraph 4) of the Revised Penal Code.

Upon entering Humility Street, Multinational Village, Parañaque City, the police operatives spotted Yang driving his black Toyota Innova which they tried to flag down. However, instead of stopping, Yang sped off prompting the team to gave chase until he was cornered at the gate of Multinational Village, Parañaque City. The police operatives then instructed Yang to alight from his vehicle, showed him the Warrant of Arrest, and effected his arrest. PO3 Nabarte, together with PO2 De Guzman, PO2 Cubyan and Yang, boarded the Toyota Innova and proceeded to Yang's residence to implement the Search Warrant while the rest of the team followed. Upon their arrival thereat, and in the presence of Barangay Kagawads Espiritu and Cristobal who were summoned to witness the search, the police operatives presented the search warrant to Yang and informed him of the purpose of the search and his constitutional rights.

Afterwards, the police operatives, together with Yang and Barangay Kagawads Espiritu and Cristobal, entered Yang's two-storey house and started searching the ground floor but found nothing. They proceeded thereafter to the second floor and the police operatives started searching the master's bedroom and middle room, but no illegal drugs were likewise found. However, the police operatives found a room at the right portion of the second floor which was locked with a fingerprint scanner, so the police operatives requested Yang to open the said room. Thereat, the PO3 Nabarte recovered a white paper bag labelled "VNC" and inside of which was a transparent plastic bag labelled "TBY SHOP.COM". The said transparent plastic bag, on the other hand, contained a yellow SM plastic bag which contained two (2) transparent bags of powdery white substance suspected to be Ketamine. PO3 Nabarte then placed the marking "JENN" and the date on the recovered pieces of evidence inside the room.

After searching Yang's house, the police operatives proceeded to search the Toyota Innova driven by Yang, still in the latter's presence and Barangay Kagawads Espiritu and Cristobal. When the police operatives opened the trunk, PO3 Nabarte recovered two (2) travelling bags. The first bag was colored black and gray, with label "Structure Sport" which was immediately marked by PO3 Nabarte as EXH B JENN 04-19-18. Inside the said bag were three (3) plastic bags tied with straw, which they also marked as EXH B-1 JENN 04-19-18, EXH B-2 JENN 04-19-18, and EXH B-3 JENN 04-19-18.

The second bag was colored black and blue, with label "Hilfiger," which was immediately marked by PO3 Nabarte as EXH C JENN 04-19. Inside the said bag were two (2) transparent plastic bags tied with straw and containing white powdery substance. PO3 Nabarte marked the plastic bags with EXH C-1 JENN 04-19-18 and EXH C-2 JENN 04-19-18.

The police operatives also recovered machines used to produce credit cards. They then conducted a physical inventory of the confiscated items and also took pictures thereof. Barangay Kagawad Espiritu subsequently issued a Certification of orderly search relative to the implementation of the search warrant, which Yang refused to sign. PO3 Nabarte, on the other hand, issued four (4) Receipts of Property Seized enumerating all of the foregoing confiscated items, which were signed by Barangay Kagawads Espiritu and Cristobal. PO3 Nabarte likewise issued a Certificate of Orderly Search signed by Barangay Kagawads Espiritu and Cristobal. Yang, however, refused to sign said Certificate.

Thereafter, Yang was brought to Camp Crame, Quezon City, for booking and investigation together with the confiscated items. The police operatives likewise returned thereat. At the said office, a representative from the Department of Justice in the person of Prosecutor Manabat was waiting. The police operatives then showed the confiscated items to Prosecutor Manabat. The police operatives likewise prepared a Request for Laboratory Examination for the confiscated items. Together with the request, all of the foregoing seized items were submitted to the PNP Crime Laboratory by PO3 Nabarte.

Forensic Chemist Abad of the PDEA Laboratory Service, who received the seized items, conducted a laboratory examination on the said items. From among the specimens submitted for chemical examination, only the bag of white crystalline substance marked as EXH C-2 JENN 04-19-18 gave positive result for Ketamine Hydrochloride, while the rest tested negative for dangerous drugs as contained in her Final Chemistry Report No. DD-073-0820 dated 20 April 2008.^[5] (Citations omitted)

Meanwhile, Yang gave a completely different re-telling of what transpired. Thus:

At around 1:00 o'clock in the afternoon of 19 April 2008, Yang was about to leave his house enroute [sic] to Angeles City, Pampanga, to bring computers and laptops when he noticed several persons and vehicles outside his house. He was ordered to stop but fearing that it might be a kidnapping situation, Yang drove towards the gate of the village to report to the security guards the incident and that he was being followed. The security guards informed Yang that the men following him introduced themselves as policemen. The police officers then informed Yang that he was driving a carnapped vehicle and was asked to produce the official receipt and certificate of registration. After handing over to the police officers the papers of the vehicle, Yang was handcuffed and was driven around Multinational Village. He then noticed that his car was no longer there. After half an hour, the police officers brought Yang to his house where he was shown a search warrant. He was directed to open his house where his wife, child, and househelp were. Upon entering his house, Yang saw computers and laptop which, he was told, were to be used as evidence against him. After being informed of the procedure of the search, the police officers started to search the entire house. Later, Yang was handed the car key and was asked to open the doors. When he opened the trunk, he was surprised to see bags instead of the computers and laptops that were supposedly inside the trunk. The bags were opened by the police operatives and Yang was informed that the said bags contained drugs.

Yang further testified that he was taken to Camp Crame, Quezon City, where the police operatives demanded Php 10,000,000.00 from him. When his lawyer arrived, the latter was able to negotiate and lower the amount being demanded to Php 1,000,000.00 in exchange for the dropping of the case against Yang. The latter's godmother, Evelyn Sy Ting, provided the amount of Php 1,000,000.00. Yang's girlfriend, Mary Jane Gloria, saw his lawyer hand over the said amount of the police officers. Yang also testified that he had a prior case in Quezon City involving credit cards but this was dismissed.^[6] (Citations omitted)

After trial, the RTC rendered judgment finding Yang guilty beyond reasonable doubt of violating Section 11, Article II of RA 9165.^[7] The dispositive portion of the decision reads:

WHEREFORE, premises considered, this Court finds accused CHIH CHIEN YANG in Criminal Case No. 08-0517, GUILTY beyond reasonable doubt for Violation of Sec. 11, Art. II, R.A. 9165 and considering the weight of ketamine hydrochloride found in his possession which is 9.9 kilograms, he is hereby sentenced to suffer the penalty of life imprisonment and to pay a fine of Php 1,000,000.00.

Further it appearing that the accused CHIH CHIEN YANG is detained at the Metro Manila District Jail (MMDJ), Special Intensive Care Area (SICA), Camp Bagong Diwa, Taguig City and considering the penalty imposed, the OIC-Branch Clerk of Court is hereby directed to prepare the Mittimus for the immediate transfer of said accused from the MMDJ-SIC to the New Bilibid Prisons, Muntinlupa City.

The representative sample of the ketamine hydrochloride subject of this case is forfeited in favor of the government and the OIC-Branch Clerk of Court is likewise directed to immediately turn over the same to the Philippine Drug Enforcement Agency (PDEA) for proper disposal pursuant to Sec. 21 of RA 9165 and Supreme Court OCA Circular No. 51-2003.

SO ORDERED.^[8]

The RTC found Yang's defense of denial and frame-up too weak to overcome the presumption of regularity in the performance of duties extended in favor of the police officers. It was pointed out that personalities that were allegedly present during his arrest and could testify as to its irregularity were not presented as witnesses by the defense. The trial court, nevertheless, acknowledged that it was the prosecution that had the burden to prove Yang's guilt considering that the latter enjoys the presumption of innocence. On this score, the RTC was convinced that the prosecution was able to discharge this burden. The RTC gave credence to the testimonies of the police officers narrating what had transpired during the implementation of the arrest warrant and search warrant issued against Yang. Also, while the RTC observed some departure from the requirements prescribed in Section 21 of RA 9165, the court did not see this as fatal for the prosecution as there was substantial compliance with the law and the integrity and evidentiary value of the seized items were preserved. All told, the RTC found that all the elements of the crime charged were established by the prosecution.^[9]

Aggrieved, Yang appealed his conviction to the CA.

Ruling of the CA

The CA, in its assailed Decision^[10] dated 22 December 2011, affirmed the RTC's ruling and disposed of Yang's appeal in this manner:

WHEREFORE, premises considered, the instant Appeal is DENIED. The Decision dated 15 April 2013 of the Regional Trial Court of Parañaque City, Branch 259, in Criminal Case No. 08-0517, is hereby AFFIRMED.

SO ORDERED.^[11]

The CA agreed with the trial court that the elements of the crime charged was fully established. It was shown that Yang had free and conscious constructive possession of the seized drugs without having any legal authority for such possession. The CA also found no reason to interfere with the factual findings of the RTC with regard to the credibility of the prosecution witnesses. As for the defenses that Yang offered, the CA found them underwhelming to defeat the evidence presented to prove his guilt. The appellate court is in accord with the RTC that in the absence of clear and convincing proof that the police officers had ill motive to implicate Yang, their testimonies with respect to the implementation of the warrants must be given full faith and credence. The CA also saw as unbelievable Yang's story of extortion. Considering the seriousness of the allegation, Yang failed to substantiate the same by evidence. Further, the alleged extortion is belied by the certification issued by the barangay officials attesting to the orderly implementation of the search warrant.^[12]

Yang now comes before the Court appealing the CA's affirmance of his conviction. When required to submit their respective briefs,^[13] both Yang and the Office of the Solicitor General (OSG) manifested their lack of desire to do so.^[14]

Issue

The sole issue for this Court's resolution is whether Yang was correctly convicted for violating Section 11, Article II of RA 9165.

In his Brief for the Accused-Appellant^[15] which he filed before the CA, Yang merely claimed that he was illegally arrested without a warrant and thus, the evidence secured from the warrantless arrest should be considered inadmissible.^[16]

Ruling of the Court

We affirm Yang's conviction.

At the onset, Yang's assertion that he was illegally arrested without a warrant was already addressed adequately by the CA. We agree with the CA that apart from the search warrant against him, the police officers were also implementing an arrest warrant issued in connection with another criminal charge for Estafa he was facing. These warrants are on record and presented in evidence.^[17] Thus, there is no reason to doubt the truth about the legality of Yang's arrest.

More importantly, We find no reason to disturb the RTC's and CA's uniform ruling that the prosecution was able to establish all the elements of the crime of illegal possession of dangerous drugs. In illegal possession of dangerous drugs, the elements are: (1) the accused is in possession of an item or object which is identified to be a prohibited drug; (2) such possession is not authorized by law; and (3) the accused freely and consciously possessed the said drug.^[18]

Here, it was shown that Yang had in his free and conscious possession, 9.9 kilograms of powdery white substance that later tested positive for ketamine hydrochloride. Indeed, the seized drug was recovered from the vehicle that Yang was seen driving.

The fact that ketamine hydrochloride is a dangerous drug is also established. According to the World Health Organization (WHO), misuse and abuse of Ketamine Hydrochloride have the following main neurobehavioral effects: anxiety, agitation, changes of perception (e.g. loss of notion of danger, visual disturbances), and, disorientation and impairment of motor functions, such as ataxia and dystonic reaction. In these conditions, the intoxicant's self-control is drastically impaired, rendering said person a potential source of physical harm or injury, not only to himself or herself, but also to others. Other common side-effects also include: slurred speech, dizziness, blurred vision, palpitations, chest pains, vomiting, and insomnia.^[19] News reports also described that in smaller doses, Ketamine Hydrochloride produces a mild and dreamy feeling. However, hallucinogenic effects happen when large quantities are consumed.^[20] In 2005, the Dangerous Drugs Board issued Board Resolution No. 3, s. 2005, classifying ketamine hydrochloride as a dangerous drug.^[21]

Finally, Yang failed to show any lawful authority to possess the confiscated ketamine.

The Court also agrees with the RTC that despite of the police officer's failure to observe fully the requirements under Section 21 of RA 9165, the prosecution was able to prove the corpus delicti of the crime.

Indeed, in every prosecution of violations of RA 9165, including illegal possession of dangerous drugs, the prosecution is mandated to present the corpus delicti of the crime, i.e., the seized drugs, as evidence in court. Concomitantly, the prosecution has the burden to prove beyond reasonable doubt the identity of the dangerous drugs by showing that the drugs offered in court as evidence were the same substances bought or recovered from the accused.^[22]

In this regard, the chain of custody rule embodied in Section 21 of RA 9165 was designed precisely to ensure that all the rights of the accused are guaranteed and the credibility of the corpus delicti safeguarded.^[23] Part of the chain of custody rule, RA 9165 requires that the marking, physical inventory, and photography of the seized items be conducted immediately after the seizure and confiscation of the same. It was made compulsory that the physical inventory and photograph-taking be done in the presence of the accused or the person from whom the items were seized, or his representative or counsel, as well these required witnesses: (a) if prior to the amendment of RA 9165 by RA 10640^[24] on 07 August 2014,^[25] "a representative from the media AND the Department of Justice (DOJ), and any elected public official"; or (b) if after said amendment, "[an] elected public official and a representative of the National Prosecution Service OR the media." These witnesses were required by law specifically "to ensure the establishment of the chain of custody and remove any suspicion of switching, planting, or contamination of evidence."^[26]

Here, the criminal act was committed on 19 April 2008 or before the amendment of RA 9165. Thus, aside from the accused or his representative, three (3) specific witnesses were required during the conduct of inventory and photograph-taking of the seized drugs. However, it appears that in the present case, there were no representatives from the media and the DOJ present as witness to these procedures. Only the three (3) barangay officials witnessed the conduct of inventory and photograph-taking of the seized items; and while a DOJ representative later on appeared in the Anti-Illegal Drugs Special Operations Task Force office and saw the seized items, this hardly satisfies the requirement under Section 21 of RA 9165.

Nonetheless, this Court find this misstep not fatal for the prosecution's cause. In People v. Lung Wai Tang,^[27] the Court held that the large quantity of drugs seized renders unlikely the possibility of planting or tampering evidence. Thus:

This Court finds unreliable accused-appellant's version that he was merely framed-up. The considerable quantity of seized drugs totaling 7.9 kilograms renders his claim that the seized drugs were planted by the police officers difficult to believe. Unlike miniscule amounts, a large quantity of drugs worth millions is not as susceptible to planting, tampering, or alteration[.]

x x x

Strict adherence to the procedural safeguards is required where the quantity of illegal drugs seized is small, since it is highly susceptible to planting, tampering, or alteration of evidence. On the other hand, large amounts of seized drugs are not as easily planted, tampered, or manipulated. Here, the considerable quantity of shabu consisting of almost eight (8) kilograms provides strong probative value favoring the prosecution's version of events. (Emphasis supplied)

In a similar fashion, the drugs found in Yang's possession are of considerable amount, weighing 9.9 kilograms. The evil sought to be prevented by a strict adherence to the procedural safeguards under RA 9165 is not present here. Thus, the Court finds it proper to apply in this case the pronouncements made in Lung Wai Tang.

Further, the Court notes that in the course of serving the search and arrest warrants against accused-appellant at the specified location of the search, the police officers spotted accused-appellant driving his vehicle. When flagged down, accused-appellant tried to evade the police officers by speeding away, and a chase then ensued. Accused-appellant was finally apprehended at the gate of Multinational Village. Jurisprudence has repeatedly declared that flight is an indication of guilt. The flight of an accused, in the absence of a credible explanation, would be a circumstance from which an inference of guilt may be established for a truly innocent person would normally grasp the first available opportunity to defend himself and assert his innocence.^[28]

More importantly, the testimonies of the key prosecution witnesses Police Officer 3 Jose Nabarte (PO3 Nabarte) and Philippine Drug Enforcement Agency Chemist Maria Criser Abad (PDEA Chemist Abad), were able to account for the movement and condition of the seized drug from the time of seizure up until its presentation in court. They testified:

PO3 Jose Nabarte
Q:	When you proceeded to your office at Camp Crame, Quezon City, where were the evidences [sic] recovered at that time?
A:	Inside the Innova, Ma'am.
Q:	Who were inside the Innova where the evidence recovered was placed?
A:	The suspect, myself, and the arresting officer PO2 de Guzman and was driven by PO2 Cubyan, Ma'am.
COURT:
Q:	So there was no other persons at that time had access to the alleged dangerous drugs?
A:	None, your Honor.
x x x
Q:	So what happened after the preparation of the Request for Laboratory Examination?
A:	I brought the recovered evidence to the PDEA, your Honor.
Q:	Who were your companions?
A:	Our team leader Ochave, and PO2 de Guzman, your Honor.
Q:	While on the Police Station, nobody had access to the same drugs confiscated except you and the three (3) others?
A:	Yes, your Honor.
Q:	Up to the time you brought these items to the crime laboratory?
A:	PDEA, your Honor.
Q:	To the PDEA?
A:	Yes, your Honor.
Q:	What happened to the PDEA?
A:	I had the request received and the evidence surrendered to them, your Honor.
PROS. ROMA:
Q:	Mr. Witness, did you bring the recovered evidence to the PDEA?
A:	On the same day, around past 10:00 o'clock.
COURT:
Q:	10:00 o'clock in the evening?
A:	Yes, your Honor.
PROS.ROMA:
Q:	Now you mentioned of the Request for Laboratory Examination. Now, if the Request for Laboratory Examination which you said you brought together with the recovered evidence will be shown to you, can you identify it?
A:	Yes Ma'am.
Q:	Showing now to you a Request for Laboratory Examination dated April 19, 2008, will you please examine and identify this document?
A:	This is one of our requests to PDEA, Ma'am and this is my signature.
COURT:
Q:	Who received this document?
A:	The Chemist Maria Criser Abad, your Honor.
Q:	From whom did she received this request?
A:	From me, your Honor.
Q:	It is indicated in the stamp receipt your name and the name of the chemist?
A:	Yes, your Honor.[29]
Maria Criser Abad
Q:	Miss Witness, why are you here today?
A:	I received a subpoena from the court.
Q:	What did you do after you receive [sic] the subpoena from the court?
A:	I coordinated with the PDEA laboratory service since I am already not connected with the agency so I permitted [sic] from them for the  evidence and the reports.
Q:	After you coordinated with the PDEA laboratory service, what did you do next, if any?
A:	I informed them about the hearing because I have to receive the evidence and the reports and then accompanied me for this hearing.
Q:	And do you have with you the evidence stated in the subpoena?
A:	Yes, ma'am.
x x x
Q:	Now when you received the Request for Laboratory Examination, this is the only document you received?
A:	Yes, Ma'am.
Q:	What did you do upon receiving this Request?
A:	I checked the request for Examination and I checked whether the specimens indicate in the Request are the specimens submitted to me.
x x x
Q:	After checking the specimens that were submitted to you and that in the Request for [L]aboratory Examination, what did you find out?
A:	The specimens indicated in the Request are the specimens submitted to me.
x x x
Q:	After that, what did you do next, if any?
A:	I received all of it. I placed the rubber stamp of the PDEA Laboratory Service and I indicated all the necessary information and placed my signature then I proceeded with the examination of the specimens.
x x x
Q:	What did you do after the confirmatory tests was [sic] done?
A:	I sealed the samples and turned them over to the evidence custodian.
Q:	And how did you seal the evidence or the specimen?
A:	I placed my markings and my initials and sealed them.
Q:	Do you have with you the specimen?
A:	Yes, ma'am.
Q:	So, Miss Witness, through the markings, you will be able to identify the specimens which were turned over to you and which were the subjected [sic] to the laboratory examination?
A:	Yes, ma'am.[30]

It is worthy to note that PDEA Chemist Abad was able to identify and authenticate all the markings and signatures she put on the evidence that were submitted to her. Clearly, her and PO3 Jose Nabarte's testimonies show that the integrity and evidentiary value of the seized drugs remained intact. There is no doubt that the items recovered from Yang's possession are the same pieces of evidence presented in court.

WHEREFORE, the Appeal is hereby DENIED. Accordingly, the Decision promulgated by the Court of Appeals on 04 September 2015 in CA G.R. CR-HC No. 06171 which affirmed the Judgment dated 15 April 2013 rendered in Criminal Case No. 08-0517 of the Regional Trial Court, Branch 259, Parañaque City, finding Chih Chien Yang guilty beyond reasonable doubt of Section 11, Article II of Republic Act No. 9165, and sentencing him to suffer the penalty of life imprisonment and to pay a fine of P1,000,000.00. is AFFIRMED in toto. Accused-appellant is likewise ORDERED to pay the costs of suit.

All the monetary awards shall earn interest at the legal rate of six percent (6%) per annum from date of finality of this judgment until fully paid.

SO ORDERED.

Leonen, (Chairperson), Rosario, and Dimaampao,^** JJ., concur.
Carandang,^* J., on official leave.

---

^* On official leave per Special Order No. 2851 dated 07 October 2021.

^** Designated additional Member per Special Order No. 2839.

^[1] Rollo, pp. 2-14. Penned by Associate Justice Zenaida T. Galapate-Laguilles and concurred in by Associate Justices Mariflor P. Punzalan Castillo and Carmelita Salandanan Manahan.

^[2] CA rollo, pp. 40-46. Penned by Presiding Judge Danilo V. Suarez.

^[3] Rollo, p. 3.

^[4] Id.

^[5] Id. at 4-7.

^[6] Id. at 7-8.

^[7] CA rollo, p. 46.

^[8] Id.

^[9] Id. at 43-46.

^[10] Rollo, pp. 2-14.

^[11] Id. at 13-14.

^[12] Id. at 10-13.

^[13] Id. at 24.

^[14] Id. at 27-29 and 32-34.

^[15] CA rollo, pp. 29-38.

^[16] Id. at 35.

^[17] Id. at 5 and 10.

^[18] People v. Serrano, 634 Phil. 406 (2010).

^[19] Ketamine: Update Review Report <https://ww.who.int/medicines/areas/quality_safety/6_2_Update.pdf> (visited 18 October 2021).

^[20] Cops wants party drug labeled 'dangerous' <https://www.philstar.com/metro/2005/03/31/272096/cops-­want-party-drug-labeled-145dangerous146> (visited 18 October 2021).

^[21] SECTION 1. CLASSIFICATION AS A DANGEROUS DRUG - any material, compound, mixture or preparation which contains any quantity of KETAMINE, including its salts, isomers, and salts of isomers within the specific chemical designation, by whatever official, common or unusual or brand name or designation is classified as a dangerous drug.

^[22] People v. Angngao, 755 Phil 597, 612 (2015). See also People v. Ruiz, G.R. No. 243635, 27 November 2019.

^[23] Tañamor v. People, G.R. No. 228132, 11 March 2020.

^[24] AN ACT TO FURTHER STRENGTHEN THE ANTI-DRUG CAMPAIGN OF THE GOVERNMENT, AMENDING FOR THE PURPOSE SECTION 21 OF REPUBLIC ACT NO. 9165, OTHERWISE KNOWN AS THE COMPREHENSIVE DANGEROUS DRUGS ACT OF 2002. Approved: 15 July 2014.

^[25] See People v. Gutierrez, G.R. No. 236304, 05 November 2018.

^[26] People v. Bangalan, G.R. No. 232249, 839 Phil. 455 (2018).

^[27] G.R. No. 238517, 27 November 2019.

^[28] People v. Medina, 788 Phil. 115 (2016).

^[29] TSN, 01 February 2012, pp. 53-57.

^[30] TSN, 25 August 2011, pp. 10-24.