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PEOPLE v. ARNOLD MARTINEZ Y ANGELES

FACTS:

On September 2, 2006, at around 12:45 PM, a concerned citizen reported to PO1 Bernard Azardon at the Police Community Precinct II in Dagupan City that a pot session was occurring in the house of Rafael Gonzales in Trinidad Subdivision. Acting on this information, PO1 Azardon, PO1 Alejandro Dela Cruz, and members of the SWAT team proceeded to the location and arrested Orlando Doria as he was exiting the house. Inside the house, they found and arrested Rafael Gonzales, Arnold Martinez, Edgar Dizon, and Rezin Martinez. The police seized multiple open plastic sachets containing shabu residue, pieces of rolled used aluminum foil, and other related paraphernalia. These items were turned over to the Pangasinan Provincial Police Crime Laboratory, where 115 plastic sachets, 11 pieces of rolled used aluminum foil, and 27 out of 49 pieces of used aluminum foil tested positive for methamphetamine hydrochloride. Subsequent drug tests found all arrestees except for Doria positive for methamphetamine hydrochloride. The defense claimed that the accused were innocently present in the area to meet an acquaintance when they were suddenly arrested by police officers without any ongoing pot session or possession of illegal drugs. The trial court dismissed the case against Doria on a demurrer to evidence but found the remaining accused guilty based on the constructive possession of the drugs and the conspiracy among them. The Court of Appeals affirmed the trial court's decision, noting sufficient evidence for constructive possession and upholding the presumption of regularity in the performance of official duties by the police, despite some procedural irregularities. The accused subsequently appealed to the Supreme Court.

ISSUES:

  1. Whether the accused were having a pot session at the time of their arrest.

  2. Whether the shabu paraphernalia planted by the police justified the arrest of the accused-appellants without a warrant.

  3. Whether the corpus delicti was sufficiently established.

  4. Whether the uncorroborated testimony of PO1 Azardon was sufficient to convict the accused-appellants of the crime charged.

  5. Whether there was sufficient evidence to establish the chain of custody of the alleged confiscated drug.

RULING:

  1. On the legality of the arrest and admissibility of evidence

    • The Supreme Court found that the arrest of the accused was illegal as it was based solely on the tip from a concerned citizen who himself only heard the information from someone else.

    • Since the arrest was illegal, the consequent search and seizure became illegal. Therefore, the evidence obtained during the illegal warrantless arrest was inadmissible.

  2. On the chain of custody

    • The court ruled that there was a significant failure to maintain the chain of custody of the evidence.

    • Irregularities such as the absence of proper marking, delay in issuing the Confiscation Receipt, and dubious handling of the seized items rendered the chain of custody broken.

    • Due to these irregularities, the corpus delicti was not adequately established.

  3. On the presumption of regularity

    • The presumption of regularity in the performance of official duties cannot stand when there is a significant deviation from the regular performance of duties. In this case, the official acts were shown to be irregular, thus the presumption cannot prevail over the presumption of innocence of the accused.

Based on the above findings, the Supreme Court reversed and set aside the decision of the Court of Appeals and acquitted the accused on the grounds of illegal arrest, the inadmissibility of evidence, and failure to establish the chain of custody.

PRINCIPLES:

  1. Probable Cause for Warrantless Arrest Personal knowledge by the arresting officers of the facts indicating that the accused committed the offense is necessary. Mere tip-offs without corroboration are insufficient.

  2. Fruit of the Poisonous Tree Doctrine Evidence obtained from an illegal arrest or search is inadmissible in court.

  3. Chain of Custody Rule The chain of custody in drug cases must be shown with moral certainty by tracking the movement of the seized drugs from the accused to the police, to the chemist, and finally to the court.

  4. Presumption of Innocence vs. Presumption of Regularity The presumption of regularity in the performance of official duties cannot prevail over the presumption of innocence where there is evidence of significant irregularities.

  5. Compliance with Section 21 of R.A. No. 9165 The procedures for the custody and handling of seized drugs must be strictly adhered to ensure their integrity and evidentiary value. Non-compliance, especially without justifiable grounds, results in the inadmissibility of evidence and failure to prove the corpus delicti .