Reas v. People

FIRST DIVISION

[G.R. No. 248228. May 3, 2021.]

ROLAND G. REAS, petitioner, vs.PEOPLE OF THE PHILIPPINES, respondent.

NOTICE

Sirs/Mesdames :

Please take notice that the Court, First Division, issued a Resolution datedMay 3, 2021which reads as follows:

"G.R. No. 248228 (Roland G. Reas v. People of the Philippines). — This is a Petition for Review on Certiorari1 filed by Roland G. Reas (Reas) assailing the Decision 2 dated May 24, 2019 of the Court of Appeals (CA) in CA-G.R. CR No. 01678-MIN. The CA affirmed the Decision 3 dated October 18, 2017 of the Regional Trial Court (RTC) of Panabo City, Branch 34, convicting Reas for violations of Sections 11 (illegal possession of dangerous drugs) and 12 (illegal possession of drug paraphernalia), Article II, of Republic Act No. (R.A.) 9165, otherwise known as the "Comprehensive Dangerous Drugs Act of 2002," as amended.

The accusatory portions of the two Informations filed with the RTC read:

Criminal Case No. CRC-213-2015 (Violation of Section 11)

That on or about June 11, 2015, in the City of Panabo, Davao del Norte, Philippines, and within the jurisdiction of this Honorable Court, the above-named accused, without being authorized by law, willfully, unlawfully and knowingly had in his possession, control and custody seven (7) sachets of transparent cellophane containing methamphetamine hydrochloride or "shabu" found inside a small plastic container, weighing:

"RES-1" — 0.0219 gram

with their pertinent markings, respectively, all dangerous drug.

CONTRARY TO LAW. 4

Criminal Case No. CR-DRG 2014-352 (Violation of Section 12)

That on or about June 11, 2015, in the City of Panabo, Davao del Norte, Philippines, and within the jurisdiction of this Honorable Court, the above-named accused, without being authorized by law, willfully, unlawfully and knowingly had in his possession, control and custody four (4) lighters and six (6) aluminum foils, drug paraphernalia used to consume, administer and introduce methamphetamine hydrochloride or "shabu" into the body, a dangerous drug.

CONTRARY TO LAW. 5

On September 23, 2015, Reas was arraigned and pleaded not guilty to both charges. Thereafter, a joint trial on the merits ensued with the prosecution presenting Police Officer 3 Randy E. Sta. Maria (PO3 Sta. Maria) as its sole witness. The prosecution dispensed with the presentation of Senior Police Officer 3 Jimwel Angkla (SPO3 Angkla) after the defense made a stipulation on his supposed testimony that he was among the police officers who participated in the implementation of the search warrant. 6 cEaSHC

PO3 Sta. Maria testified that at around 8:00 a.m. of June 11, 2015, he went to the intelligence section of the Panabo City Police Office for a briefing about the Search Warrant 7 secured by PO1 Edwin Malinao (PO1 Malinao) against Reas alias "KongKong" residing at Purok 3-C, Luzviminda Subdivision, Barangay San Francisco, Panabo City. He was designated as the seizing officer, while three other police were assigned as perimeter guards and another officer was tasked to coordinate with the barangay official and media representative. SPO3 Angkla was the team leader. Per record of the Police Blotter, 8 the team departed from the police station at around 9:30 a.m. They located the house of Reas with the help of PO1 Malinao and SPO3 Angkla who knew its location. While the team was in front of the house introducing themselves as police officers intending to implement a search warrant, Reas who was at the porch with two companions immediately ran inside the house and exited at the kitchen. Reas was caught by PO1 Malinao at the exit door. The two companions of Reas stay put on the porch as they were restrained by SPO3 Angkla and Officer Caasi. PO1 Malinao brought Reas in the living room. PO3 Sta. Maria and Officer Caasi as well as Councilor Hugo and a media representative then entered the house. PO3 Sta. Maria presented the search warrant and Councilor Hugo explained the same to Reas. Reas, Councilor Hugo, and the media representative were present during the search. 9

PO3 Sta. Maria searched the living room and recovered four lighters on top of the cabinet. He then went to the master's bedroom at the left side of the living room, where he found a white backpack hanged at the back of the door. He shook the backpack after opening its compartment. Six aluminum foils, a plastic container containing seven sachets of shabu, a t-shirt, and a wristwatch fell. PO3 Sta. Maria also searched the kitchen but found nothing. He did not search the room of the sister of Reas per advise of their team leader. 10 The team proceeded to the porch of the house where PO3 Sta. Maria conducted the tagging, inventory, and photographing of the items seized. 11 PO3 Sta. Maria marked the 7 sachets of shabu with his initials, "RES-1," "RES-2," "RES-3," "RES-4," "RES-5," "RES-6," and "RES-7." He also wrote the name of the suspect, time, date, and place of commission, as well as his name and signature on a paper attached to each of the heat-sealed transparent cellophane containing white crystalline substance. 12 He prepared the Inventory of the Property Seized, 13 Certification of Legally and Orderly Execution of Search Warrant, 14 and Receipt of Evidence Confiscated 15 at the crime scene in the presence of the representative from the media, barangay official, and Reas. 16 Reas refused to sign the documents, claiming that he was not the owner of the house. He also refused to receive a copy of the Certification of Legally and Orderly Execution of Search Warrant and Receipt of Evidence Confiscated despite the explanation of PO3 Sta. Maria and Councilor Hugo. Thus, PO3 Sta. Maria just left copies of the said documents at the main door of the house. 17

The team went to the police station together with Reas. PO3 Sta. Maria was in custody of the seized items from the crime scene going to the police station and the team's arrival was recorded in the police blotter. He presented the items to the desk officer, then he prepared the Chain of Custody 18 and Memorandum of Request for Laboratory Examination. 19 He brought Reas and the confiscated items to the PNP Crime Laboratory Tagum City for examination. Per Chemistry Report No. D-238-2015, 20 the seven heat-sealed transparent plastic packs each containing white crystalline substance tested positive for methamphetamine hydrochloride or shabu. 21

The defense opted not to present evidence as it strongly believed that the chain of custody requirements was not complied with for the failure of the prosecution to present all those who handled the drugs. The RTC directed the parties to submit a memorandum but none complied. 22

Ruling of the Regional Trial Court

In its Decision 23 dated October 18, 2017, the RTC convicted Reas of the crimes charged. For illegal possession of dangerous drugs, Reas was sentenced to suffer the penalty of imprisonment of fourteen (14) years and one (1) day, as minimum, to seventeen (17) years as maximum, and to pay a fine in the amount of P300,000.00. For illegal possession of drug paraphernalia, Reas was sentenced to suffer the indeterminate penalty of six (6) months and one (1) day, as minimum, to four (4) years as maximum, and to pay a fine in the amount of P10,000.00. 24

First, the RTC held that the prosecution proved beyond reasonable doubt the presence of all the elements of illegal possession of dangerous drugs, which are: (a) the accused is in possession of an item or object identified to be a prohibited drug; (b) such possession is not authorized by law; and (c) accused freely and consciously possessed the said drug. Likewise, all the elements of illegal possession of drug paraphernalia were established, which are: (a) possession and control by the accused of any equipment, apparatus, or other paraphernalia for or intended for smoking, consuming, administering, injecting or introducing any dangerous drug into the body; and (b) such possession is not authorized by law. Here, PO3 Sta. Maria recovered seven sachets of shabu, six aluminum foils, and four lighters during the search conducted in the house of Reas. 25

Second, the RTC ruled that the search in the house of Reas was valid. The search was done in the presence of Reas, a representative of media, and a barangay official. The Inventory of the Property Seized, Receipt of Evidence Confiscated and Certificate of Peacefully and Orderly Search were left in the house of Reas because he refused to sign and receive the documents. A return of the search warrant was also made by the implementing officer to the issuing court. 26 CTIEac

Third, the RTC rejected the argument that the corpus delicti of the crime was not established because the prosecution failed to present the persons who handled the seized items. It found that there was substantial compliance to the chain of custody rule. PO3 Sta. Maria marked the seized items at the crime scene in the presence of the accused and the inventory was conducted in the presence of the intended witnesses. He took custody of the items from the crime scene going to the police station up to the time that he brought the same to the PNP Crime Laboratory in Tagum City, and the said Office through Officer Ruffy Federe (Officer Federe) subsequently turned over the same to the court for its appreciation. Thus, the RTC declared that the drugs and the paraphernalia were duly accounted for from the moment of their seizure up to the time they were presented in court. The integrity and evidentiary value of the seized items were properly preserved. 27

Further, the RTC noted that the non-presentation of the forensic chemist PSI Virginia Gucor (PSI Gucor), who examined the seized items, and Officer Federe, who received the items from PO3 Sta. Maria, will not in any way affect the integrity and evidentiary value of the seized drug since the Chemistry Report prepared by PSI Gucor and the Chain of Custody signed by her, Officer Federe, and PO3 Sta. Maria were both stipulated by the defense. Officer Sta. Maria who personally delivered the items to Officer Federe confirmed the latter's receipt of the items and presented as proof the Chain of Custody and the Request for Laboratory Examination, which bore the stamp receipt of the Laboratory. Furthermore, all the markings found in the seven sachets of shabu, the signatures of PO3 Sta. Maria, PSI Gucor, and Officer Federe were also stipulated by the defense. 28

The RTC held that the non-presentation of the forensic chemist is an insufficient cause for acquittal as the corpus delicti in dangerous drugs cases is the dangerous drugs itself. Corpus delicti has nothing to do with the testimony of the laboratory analyst. The report of an official forensic chemist regarding a recovered prohibited drug enjoys the presumption of regularity in its preparation and under Section 44, Rule 130, of the Revised Rules of Court, entries in official records made in the performance of official duty are prima facie evidence of the facts stated therein. Hence, the Chemistry Report of PSI Gucor finding that the specimens yielded positive for shabu is conclusive in the absence of evidence showing the contrary. 29

Reas appealed to the CA.

Ruling of the Court of Appeals

In its Decision 30 dated May 24, 2019, the CA affirmed the Decision of the RTC. Preliminarily, the CA held that since the crimes charged were committed on June 11, 2015, the applicable law is R.A. 9165, as amended by R.A. 10640, 31 which was approved on July 15, 2014. It agreed with the RTC that all the elements of illegal possession of shabu and illegal possession of drug paraphernalia were duly proven by the prosecution. First, during the implementation of the search warrant, Reas was found to have in his possession seven sachets, all containing white crystalline substance inside, with a total weight of 0.4042 grams, and five aluminum foils. These were found inside Reas' white backpack, hanging at the back of his door. The contents of the sachet were marked as "RES-1" to "RES-7," and were found by PSI Gucor to contain shabu. Second, there was nothing in the record which show that Reas was authorized to possess the drugs and the drug paraphernalia. Mere possession of dangerous drugs and drug paraphernalia constitutes prima facie evidence of knowledge or animus possidendi, sufficient to convict the accused in the absence of a satisfactory explanation of such possession. Third, Reas failed to present contrary evidence to rebut his possession of the shabu and the drug paraphernalia. 32

The CA also found that the prosecution sufficiently established the crucial links in the chain of custody of the seized drugs and drug paraphernalia, thus substantially complying with Section 21 (1) of R.A. 9165, as amended. The required marking and physical inventory were conducted at the situs criminis. PO3 Sta. Maria marked the seven plastic sachets containing shabu with "RES-1" to "RES-7," respectively. He prepared the Inventory of the Property Seized, Receipt of Evidence Confiscated, and Certificate of Peacefully and Orderly Search. He signed them as the apprehending officer. These were done in the presence of Barangay Kagawad Arcilita R. Hugo, DOJ representative Ian R. Dionolla, and media representative Wolfie M. Orio, who signed the Inventory Sheet and Certification. Photographs of the marking and inventory were also taken. Thereafter, the police officers and Reas went to the Panabo Police Station. Police Superintendent Thor Valiente Punay Cuyos prepared and signed a Request for Drug Test, while PO3 Sta. Maria prepared a Chain of Custody Form. At 6:40 p.m. of the same day (June 11, 2015) PO3 Sta. Maria personally delivered the confiscated items to the PNP Crime Laboratory in Tagum. Officer Federe received the specimens. Per Chemistry Report No. D-238-2015, the seized items tested positive for shabu. 33

The CA noted that Reas neither denied being in possession of the drug paraphernalia nor refuted that the drug paraphernalia presented in court were the same drug paraphernalia recovered from him. The CA ruled that Reas failed to show that the evidence against him was tampered or meddled with. Thus, the presumption of regularity in handling of evidence by public officers and the presumption that public officers properly discharge their duties stand. 34

Lastly, the CA held that the non-presentation of the forensic chemist is not fatal to the case. The prosecution has the discretion as to how to present its case and it has the right to choose whom it wishes to present as witnesses. The CA found that it was clearly established in the record that Officer Federe received the specimens from PO3 Sta. Maria. PSI Gucor was also not subpoenaed to appear in court. More importantly, during the Preliminary Conference on November 19, 2015, the parties stipulated on the due execution, authenticity, and existence of the chemistry reports prepared by PSI Gucor. 35 SaCIDT

Undaunted, Reas filed this present petition.

Arguments of the Petitioner

In his petition, Reas argued that the chain of custody was not complied with. He alleged that the seemingly one-man show all performed by PO3 Sta. Maria was tainted with irregularities, hence the corpus delicti was not properly preserved. There was no discussion on what happened to the seized items and how their integrity was preserved from the time that PO3 Sta. Maria transported them to the police station and while at the police station for almost seven hours prior to their submission to the crime laboratory. PO3 Sta. Maria arrived at the police station at 12:00 p.m., while the confiscated items were delivered to the crime laboratory at 6:40 p.m. 36

Reas also claimed that the non-presentation of the forensic chemist crippled the case. While stipulations were entered, it was not stated who kept the items after the examination and what precautionary steps were taken in preserving the integrity of the seized items. The prosecution did not proffer any explanation why the forensic chemist's testimony was dispensed with. 37

Reas also maintained that the four lighters and five aluminum foils are not drug paraphernalia but mere ordinary things found in all households. The prosecution failed to establish a reasonable link that these confiscated items were fit or intended from smoking, consuming, administering, ingesting, or introducing dangerous drugs in the body. 38

Arguments of the People

In its Comment, 39 the Office of the Solicitor General (OSG), on behalf of the People, alleged that the petition should be dismissed for raising pure questions of fact which is inappropriate for a Rule 45 petition. While there are exceptions to the rule that this Court is not a trier of facts, none is obtaining in the case. 40 The OSG maintained that the CA did not err in affirming Reas' conviction because the prosecution proved all the elements of illegal possession of dangerous drugs and illegal possession of drug paraphernalia. More, the OSG insisted that the police officers substantially complied with the chain of custody rule. The requirement was sufficiently established by the testimony of PO3 Sta. Maria. The Chemistry Report prepared by PSI Gucor, whose findings yielded positive results for shabu and the Chain of Custody Form signed by PSI Gucor, PO3 Sta. Maria, and Officer Federe tied up the links and exchange of hands in the handling of the seized evidence. 41 The OSG also invoked the presumption of regularity in the performance of duties of the police officers as the defense failed to show that the latter were motivated with ill motive to impute such a serious crime against Reas. 42

Issue

The issue in this case is whether the CA erred in upholding Reas' conviction.

Ruling of the Court

The petition is meritorious.

We acquit Reas for illegal possession of dangerous drugs and illegal possession of drug paraphernalia for failure of the prosecution to prove his guilt beyond reasonable doubt.

To convict a person charged of illegal possession of dangerous drugs, the prosecution must establish the following: (a) the accused was in possession of an item or object identified as a prohibited drug; (b) such possession was not authorized by law; and (c) the accused freely and consciously possessed the said drug. On the other hand, illegal possession of drug paraphernalia has the following elements: (a) possession or control by the accused of any equipment, apparatus or other paraphernalia fit or intended for smoking, consuming, administering, injecting, ingesting, or introducing any dangerous drug into the body; and (b) such possession is not authorized by law. 43 The State bears not only the burden of proving the elements of the crimes, but also of proving the corpus delicti or body of the crime, 44 which in this case are the prohibited drug and the drug paraphernalia. Any doubt in the identity and integrity of the corpus delicti warrants the acquittal of the accused. 45 To remove any unnecessary doubts on the identity of the dangerous drugs and drug paraphernalia on account of switching, planting, or contamination of the evidence, the prosecution must be able to account for each link of the chain from the moment of the seizure up to the presentation in court as evidence of the corpus delicti. 46

The Chain of Custody rule is enshrined in Section 21, Article II of R.A. 9165. Since Reas allegedly committed the crimes in 2015, Section 21, as amended by R.A. 10640, 47 which took effect on July 23, 2014 governs, to wit:

(1) The apprehending team having initial custody and control of the dangerous drugs, controlled precursors and essential chemicals, instruments/paraphernalia and/or laboratory equipment shall, immediately after seizure and confiscation, conduct a physical inventory of the seized items and photograph the same in the presence of the accused or the person from whom such items were confiscated and/or seized, or his/her representative or counsel, with an elected public official and a representative of the National Prosecution Service or the media who shall be required to sign the copies of the inventory and be given a copy thereof: Provided, That the physical inventory and photograph shall be conducted at the place where the search warrant is served; or at the nearest police station or at the nearest office of the apprehending officer/team, whichever is practicable, in case of warrantless seizures: Provided, finally, That noncompliance of these requirements under justifiable grounds, as long as the integrity and the evidentiary value of the seized items are properly preserved by the apprehending officer/team, shall not render void and invalid such seizures and custody over said items. (Emphasis supplied.) cHECAS

Unlike the original text of Section 21, the amended version only requires the presence of two witnesses during the inventory and photographing of the seized items, namely: an elected public official and a representative of the National Prosecution Service (NPS) or the media. In Tumabini v. People, 48 We held that Section 21 applies whether the dangerous drugs and drug paraphernalia were seized either in a buy-bust operation or pursuant to a search warrant, such as in this case. 49

Jurisprudence summarized the four links in the chain of custody, as follows: (1) the seizure and marking, if practicable, of the illegal drug or drug paraphernalia recovered from the accused by the apprehending officer; (2) the turnover of the seized illegal drug or drug paraphernalia by the apprehending officer to the investigating officer; (3) the turnover of the illegal drug or drug paraphernalia by the investigating officer to the forensic chemist for laboratory examination; and (4) the turnover and submission of the illegal drug or drug paraphernalia from the forensic chemist to the court. 50 In this case, the prosecution failed to establish all the four links.

The first link pertains to the seizure and marking of the dangerous drugs and drug paraphernalia which should be immediately done at the place of arrest and seizure. It also includes the physical inventory and taking of photographs of the seized items in the presence of the accused and the required third-party witnesses. 51

Marking means the placing by the apprehending officer of his/her initials and signature on the items seized. It is the starting point of the custodial link. It must be done immediately after seizure of the contraband because succeeding handlers of the specimens will use the marking as reference. The marking of the evidence serves to separate the marked evidence from the corpus of all other similar or related evidence from the time they are seized from the accused until they are disposed of at the end of the criminal proceedings, thus, preventing switching, planting or contamination of evidence. 52 Aside from marking, the seized items should be placed in an envelope bag unless the type and quantity of these items require a different type of handling and/or container. The evidence bag or container shall accordingly be signed by the handling officer and turned over to the next office in the chain of custody. The purpose of placing the seized item in an envelope or evidence bag is to ensure that the item is secured from tampering, especially when it is susceptible to alteration or damage. 53

Here, while the required witnesses were present during the search, seizure, and inventory of the illegal drugs and drug paraphernalia, the records show that PO3 Sta. Maria failed to mark the drug paraphernalia consisting of four lighters and six aluminum foils. Only the seven sachets of shabu contained the initials of PO3 Sta. Maria namely: "RES-1," "RES-2," "RES-3," "RES-4," "RES-5," "RES-6," and "RES-7." In addition, PO3 Sta. Maria did not testify on how he secured the illegal drugs and drug paraphernalia upon confiscation and whether he placed them in an evidence bag or envelope.

With respect to the second link, there was no transmittal of dangerous drugs and drug paraphernalia from the seizing officer to the investigating officer. PO3 Sta. Maria, as the seizing officer, took custody of the dangerous drugs from seizure up to their turnover to the forensic chemist, while he took possession of the drug paraphernalia from confiscation up to the police station. 54 While the items did not change hands, PO3 Sta. Maria did not mention how he handled or safeguarded them or whether he was the only one with access to them.

As regards the third and the fourth links, Officer Federe, who received the dangerous drugs from PO3 Sta Maria, and PSI Gucor, the forensic chemist who examined said drugs, were not presented in court. We held in People v. Pajarin55 that in case the parties stipulate to dispense with the attendance and testimony of the forensic chemist, it should be stipulated that the forensic chemist was to testify that he/she took the precautionary steps required in order to preserve the integrity and evidentiary value of the seized item, thus: (1) that the forensic chemist received the seized article as marked, properly sealed, and intact; (2) that he/she resealed it after examination of the content; and (3) that he/she placed his/her own marking on the same to ensure that it could not be tampered with pending trial. 56

In this case, the stipulations between the prosecution and the defense during the preliminary conference before the RTC were limited only to the due execution, authenticity, and existence of the following documents: Chain of Custody Form of PNP Panabo, Chain of Custody Form PNP Crime Laboratory Tagum City, Chemistry Report No. D-238-2015, and Chemistry Report No. DT-177-2015. These documents do not show how Officer Federe and PSI Gucor took the precautionary steps required to preserve the integrity and evidentiary value of the seized items.

Moreover, the prosecution also did not present the evidence custodian, or the person to whom the alleged seized shabu was delivered after the laboratory examination. The evidence custodian could have testified on the circumstances under which he/she received the item, what he/she did with them during the time that the items were in his/her custody, or what happened during the time that the items were transferred to the trial court. The absence of the testimony of the evidence custodian likewise presents a break in the links in the chain of custody of the evidence. 57 Without the testimonies and stipulations stating the details on who delivered, when, and how the seized sachets of shabu were brought from the crime laboratory to the court, it cannot be ascertained whether the illegal drugs presented in evidence were the same ones confiscated from Reas during the search in his house. 58 AHDacC

In fine, the failure of the prosecution to account for the four links in the chain of custody left Us with no guarantee of the identity and integrity of the seized dangerous drugs and drug paraphernalia. Accordingly, Reas is entitled to an acquittal based on reasonable doubt.

WHEREFORE, the instant Petition for Review on Certiorari is GRANTED. The Decision dated May 24, 2019 of the Court of Appeals in CA-G.R. CR No. 01678-MIN is hereby REVERSED and SET ASIDE. Petitioner Roland G. Reas is ACQUITTED of the crimes charged against him, and is ORDERED to be IMMEDIATELY RELEASED, unless he is being lawfully held in custody for any other reason. The Director General of the Bureau of Corrections is DIRECTED to inform this Court of the action taken hereon within five (5) days from receipt hereof.

SO ORDERED."

By authority of the Court:

(SGD.) LIBRADA C. BUENADivision Clerk of Court

By:

MARIA TERESA B. SIBULODeputy Division Clerk of Court

 

Footnotes

1.Rollo, pp. 11-31.

2. Penned by Justice Walter S. Ong, with the concurrence of Justices Edgardo A. Camello and Florencio M. Mamauag, Jr.; id. at 38-59.

3. Penned by Presiding Judge Dax Gonzaga Xenos; id. at 87-96.

4. Records, p. 1.

5.Id. at 28.

6.Rollo, p. 88.

7. Records, p. 7.

8.Id. at 14.

9.Rollo, pp. 88-89.

10.Id. at 89-90.

11.Id. at 42.

12. Records, pp. 8-9.

13.Id.

14.Id. at 10-11.

15.Id. at 12.

16.Id. at 48.

17.Rollo, p. 90.

18. Records, pp. 17-18.

19.Id. at 19-20.

20.Id. at 26.

21.Id.

22.Rollo, p. 88.

23.Supra note 3.

24.Rollo, p. 95.

25.Id. at 91-92.

26.Id. at 92.

27.Id. at 92-93.

28.Id. at 93-94.

29.Id. at 94.

30.Supra note 2.

31. 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."

32.Rollo, pp. 45-48.

33.Id. at 54-56.

34.Id. at 56.

35.Id. at 56-58.

36.Id. at 21-25.

37.Id. at 27-29.

38.Id. at 30.

39.Id. at 125-139.

40.Id. at 129-130.

41.Id. at 130-135.

42.Id. at 135-138.

43.People v. Lumaya, 827 Phil. 473, 484 (2018).

44.People v. Manabat, G.R. No. 242947, July 17, 2019.

45.People v. Sultan, G.R. No. 225210, August 7, 2019.

46.Supra note 43.

47. Republic Act No. 10640 or 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."

48. G.R. No. 224495, February 19, 2020.

49.Id.

50.People v. Lim, G.R. No. 231989, September 4, 2018.

51.People v. Leaño, G.R. No. 246461, July 28, 2020.

52.People v. Castillo, G.R. No. 238339, August 7, 2019. Citations omitted.

53.Supra note 48.

54. Records, p. 98.

55. 654 Phil. 461 (2011).

56.Id. at 466.

57.People v. Luminda, G.R. No. 229661 (Resolution), November 20, 2019.

58.Id.