327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Can an accused be convicted of illegal possession of
dangerous drugs if they claim lack of knowledge of the bag’s contents,
especially when caught in a highly secured environment like a city jail?
People of the Philippines vs. Allan Quijano y Sanding,
G.R. No. 247558, February 19, 2020
FACTS:
In this case, Allan Quijano y Sanding was convicted of
illegal possession of dangerous drugs under Section 11, Article II of Republic
Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). He was arrested on
April 28, 2016, inside the Manila City Jail. Jail Officer (JO2) Arthur Briones
observed a regular visitor, Marivic Tulipat, receiving a suspicious light
violet bag from someone within the jail. Briones called Tulipat's attention
multiple times, and she eventually handed the bag to Quijano. Quijano also
hesitated when summoned by Briones. When Briones inspected the bag, he
discovered 735.8 grams of methamphetamine hydrochloride (shabu). Both Tulipat
and Quijano were arrested on the spot.
The defense claimed that Quijano had no knowledge of the
contents of the bag and was merely holding it for Tulipat. However, the trial
court and the Court of Appeals found this explanation insufficient, emphasizing
Quijano’s behavior during the incident, his hesitation to surrender the bag,
and his attempt to return it to Tulipat as indications of his awareness. The
trial court sentenced Quijano to life imprisonment and fined him P500,000,
which the Court of Appeals affirmed with a modification removing subsidiary
imprisonment in case of insolvency.
PRIMARY ISSUE BEFORE THE SUPREME COURT:
Did the Court of Appeals err in affirming Quijano's
conviction despite his claim of lack of animus possidendi (intent to possess)?
RULING OF THE SUPREME COURT:
The Supreme Court upheld the conviction, ruling that the
prosecution sufficiently established all elements of illegal possession of
dangerous drugs. The Court found that Quijano's claim of ignorance regarding
the bag's contents was implausible, given his actions. The Court emphasized
that possession under the law includes both actual and constructive possession,
and animus possidendi can be inferred from an accused’s actions. The court also
ruled that the chain of custody of the seized drugs was intact, despite a
slight variance in the weight of the drugs during court presentation, which was
satisfactorily explained by the forensic chemist.
DISPOSITIVE PORTION:
The Supreme Court dismissed the appeal, affirming the Court
of Appeals' decision. Allan Quijano y Sanding was convicted of violating
Section 11, Article II of Republic Act No. 9165. He was sentenced to life
imprisonment and ordered to pay a fine of P500,000.
Should an accused’s mere acceptance of an item from another
person in a highly controlled environment, such as a jail, automatically imply
intent to possess its illegal contents?
IMPORTANT DOCTRINES:
- Animus
Possidendi in Illegal Drug Possession:
- Animus
possidendi, or intent to possess, is presumed when an individual is shown
to have performed an act prohibited by law. It can be inferred from the
accused's actions, even in the absence of direct evidence of intent.
- Mere
Possession is Malum Prohibitum:
- The
crime of illegal possession of dangerous drugs is malum prohibitum,
meaning intent or malice is not necessary to convict an accused. Simply
holding the prohibited drugs, without lawful authority, constitutes the
crime.
- Chain
of Custody Rule:
- To
ensure the integrity of evidence, the prosecution must account for each
link in the chain of custody from seizure to presentation in court. A
slight variance in weight during court presentation does not necessarily
invalidate the chain of custody, especially when adequately explained.
Classification of the Case:
This case falls under Criminal Law, specifically
relating to violations of the Comprehensive Dangerous Drugs Act of 2002.
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🎓 Welcome, future lawyers
and bar takers! In this educational content, we’ll explore the Supreme Court’s
jurisprudence in People of the Philippines vs. Allan Quijano y Sanding, G.R.
No. 247558, promulgated on February 19, 2020. This case falls under Criminal
Law and is a vital reference for understanding illegal possession of
dangerous drugs under Section 11, Article II of R.A. 9165.
This content aims to help law students and bar examinees
recall critical doctrines applied by the Court, particularly the concept of animus
possidendi (intent to possess), constructive possession, and the chain of
custody rule in drug cases.
🧾 NATURE OF THE CASE:
Criminal case involving violation of Section 11, Article II
of R.A. 9165 (Comprehensive Dangerous Drugs Act of 2002).
📚 CASE DETAILS:
- Title:
People of the Philippines vs. Allan Quijano y Sanding
- Parties:
The People (plaintiff-appellee) vs. Allan Quijano y Sanding
(accused-appellant)
- G.R.
No.: 247558
- Date
of Promulgation: February 19, 2020
🧵BRIEF SUMMARY:
The accused, while inside the Manila City Jail, was caught
holding a bag containing 735.8 grams of shabu worth about ₱500,000,
handed to him by a jail visitor. He claimed ignorance of its contents. However,
the RTC and CA convicted him, citing suspicious behavior. The Supreme
Court affirmed the conviction, emphasizing animus possidendi and
validating the chain of custody.
💬 If a detainee
accepts a suspicious bag for just seconds, should they be presumed to possess
it knowingly and be liable for life imprisonment?
📘 10 IMPORTANT DOCTRINES
FROM THE CASE:
- Animus
Possidendi Is Presumed Upon Possession
Possession of illegal drugs raises a prima facie presumption of knowledge and intent to possess unless adequately rebutted. (See Decision, pp. 80–81) - Possession
Need Not Be Exclusive
Even shared dominion over a place or item can establish constructive possession under the law. (p. 10, citing People v. Tira) - Mere
Holding of Item Can Constitute Possession
Possession can be brief—so long as the individual exercised control, however fleeting. (p. 5, testimony of JO2 Briones) - The
Offense is Malum Prohibitum
Criminal intent is not required; the act itself is punishable regardless of motive. (p. 10, citing Arcilla v. CA) - Chain
of Custody Must Be Preserved
From seizure to court presentation, every link in handling the evidence must be traceable. (p. 43, citing People v. Havana) - Marking
and Inventory at the Scene
Immediate marking in the presence of key witnesses ensures integrity of the seized item. (pp. 11–12) - Slight
Variance in Weight Does Not Invalidate Evidence
Discrepancies in lab vs. courtroom weighing are acceptable if sufficiently explained. (pp. 47–50) - Constructive
Possession Applies Inside Detention Facilities
Even within a jail, possession may still be found if the accused had dominion or control. (pp. 3–5) - Behavior
of Accused Indicates Guilt
Hesitation, attempts to pass off evidence, and lack of protest suggest guilty knowledge. (pp. 80–81) - Presumption
of Regularity in Performance of Duty
Testimony of arresting officers is given weight absent evidence of improper motive. (pp. 80–81)
❓ FREQUENTLY ASKED QUESTIONS
(FAQs):
1. What crime was Allan Quijano charged with?
He was charged with illegal possession of dangerous drugs
under Section 11, R.A. 9165.
2. How much shabu was involved?
735.8 grams of methamphetamine hydrochloride, estimated at
₱500,000.
3. Did the Court accept his claim of lack of knowledge?
No. His behavior and the legal presumption of animus
possidendi outweighed his defense.
4. Why was the chain of custody questioned?
There was a slight variance in weight, but the Court found
the explanation sufficient and acceptable.
5. What penalty was imposed?
Life imprisonment and a fine of ₱500,000.
📢 DISCLAIMER:
This content is for educational purposes only. We do not
guarantee infallibility, and the material was generated using premium
artificial intelligence. Always verify with official sources and consult
legal professionals when needed.
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From <https://chatgpt.com/c/66eec131-bc24-800a-a0af-ef22c2d57559>
🎓 Welcome to this short
but valuable legal quizzer designed to help you recall important doctrines from
a real and recent criminal law case decided by the Supreme Court of the
Philippines.
This quizzer is based on the case People of the
Philippines vs. Allan Quijano y Sanding, G.R. No. 247558,
promulgated on February 19, 2020. This is a Criminal Law case
involving a charge of illegal possession of dangerous drugs.
The facts revolve around Allan Quijano, a detainee at the
Manila City Jail, who was found in possession of 735.8 grams of shabu
handed to him by a jail visitor. He claimed ignorance of the bag’s contents and
insisted he merely held it briefly. However, both the trial court and Court of
Appeals found him guilty, and the Supreme Court affirmed the conviction,
ruling that his actions indicated animus possidendi, or intent to
possess.
Stay tuned—the answer key will be provided at the end of
the video.
🧠 10 HOTS (Higher Order
Thinking Skills) Easy-Level Multiple Choice Questions
1. What was the primary legal issue raised by Allan
Quijano in his defense against the charge of drug possession?
A. Ownership of the drugs
B. Lack of criminal intent
C. Absence of intent to possess
D. Faulty laboratory results
2. What action of Allan Quijano led the authorities
to become suspicious and inspect the bag?
A. He tried to escape the jail
B. He dropped the bag and ran
C. He hesitated when summoned and tried to return the bag
D. He immediately confessed to owning the bag
3. Which of the following best describes the term constructive
possession as discussed in the case?
A. When the drugs are found in the house of the accused
B. When the drugs are possessed with intent to sell
C. When the drugs are under one’s control even if not
physically held
D. When the drugs are found in a government vehicle
4. What was the amount of shabu found in the bag
received by the accused?
A. 235 grams
B. 735.8 grams
C. 500 grams
D. 1,000 grams
5. How did the Court interpret the accused's failure
to immediately surrender the bag to authorities?
A. As a sign of innocence
B. As part of jail procedure
C. As indicative of guilty knowledge
D. As compliance with orders
6. Why did the Court reject the accused’s claim of
merely holding the bag?
A. It was inconsistent with the visitor's testimony
B. He had prior drug convictions
C. His actions showed dominion and control over the bag
D. He presented no documentary evidence
7. What was the final ruling of the Supreme Court in
this case?
A. The accused was acquitted due to lack of evidence
B. The accused was granted bail
C. The conviction was reversed for violation of rights
D. The conviction was affirmed
8. What penalty was imposed on the accused by the
Court?
A. Reclusion perpetua and ₱1,000,000 fine
B. Reclusion temporal and ₱100,000 fine
C. Life imprisonment and ₱500,000 fine
D. 12 years imprisonment and ₱50,000 fine
9. What reason was provided by the forensic chemist
for the slight variance in drug weight during court presentation?
A. The drugs were tampered with
B. The scale used in court was unstable
C. The drugs were not properly sealed
D. A different batch was used in the lab
10. Which of the following best explains the doctrine
of animus possidendi as applied in this case?
A. The person must own the drugs
B. The drugs must be for personal use
C. Intent to possess is presumed from the act of possession
D. The drugs must be in plain sight
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