G.R. No. 240126 . April 12, 2023
Jamel M. Adoma, Petitioner, vs. People of the Philippines, Respondent.

FACTS

Petitioner Jamel M. Adoma was charged with illegal possession of dangerous drugs under Section 11 of Republic Act No. 9165 . The prosecution’s evidence showed that on September 21, 2013, Troy Garma reported a robbery of his gadgets. Using GPS tracking, police traced the gadgets to Caesar Martin Pascua, who stated that Adoma had brought them for password unlocking and reformatting. At the police’s instruction, Pascua called Adoma to arrange a pickup at his house, where an entrapment was set. When Adoma arrived, received the laptops, and paid Pascua, police arrested him. A body search incidental to the arrest yielded a green plastic container tucked in his waist containing two plastic sachets of suspected shabu. The items were later marked and inventoried at the police station and tested positive for shabu. The defense claimed the arrest was unlawful and the drugs were planted, asserting that Adoma had bought the gadgets from an unknown person and that the police placed the sachets at his back during the arrest.

ISSUE

Whether the warrantless arrest of Adoma was valid, rendering the subsequent search incidental to arrest lawful, and whether the chain of custody of the seized drugs was properly established to prove his guilt beyond reasonable doubt.

RULING

No. The Supreme Court ruled that the warrantless arrest was invalid. For a valid hot pursuit arrest under Rule 113, Section 5(b) of the Rules of Court, the arresting officer must have personal knowledge of facts, based on actual observation, that the person to be arrested has just committed, is actually committing, or is attempting to commit an offense. The element of immediacy between the crime and the arrest is also required. Here, the police had no personal knowledge that Adoma had committed the robbery; their information came solely from Pascua’s statement, which was hearsay. The arrest also lacked immediacy, as the alleged robbery occurred in the morning, while the arrest happened in the evening after police investigation and planning. Consequently, the search incidental to the arrest was likewise invalid, and the seized drugs were inadmissible as fruits of the poisonous tree. Given the inadmissibility of the evidence and the failure to establish a valid chain of custody due to procedural lapses under Section 21 of RA 9165 (e.g., no photographs taken, inconsistencies in marking and turnover), Adoma’s guilt was not proven beyond reasonable doubt. The Court reversed the lower courts’ decisions and acquitted Adoma.