Primary Holding

The warrantless arrest and seizure of marijuana from Jimboy Suico were valid as incidental to a lawful arrest based on probable cause. The prosecution successfully established an unbroken chain of custody of the seized drugs, thus proving the corpus delicti and the appellant's guilt for illegal transportation of dangerous drugs under RA 9165.

Background

Police officers set up a checkpoint for a "no plate, no travel" policy based on information about a person transporting marijuana on a specific motorcycle. Jimboy Suico, matching the description, approached the checkpoint and attempted to evade it, leading to his arrest and the discovery of marijuana in his backpack and sack.

Facts

• 1. On September 4, 2011, police officers established a checkpoint in Purok 12, Poblacion, Cabanglasan, Bukidnon for a "no plate, no travel" policy.
• 2. Police received a tip about a person on a red motorcycle carrying marijuana in a backpack and yellow sack.
• 3. Jimboy Suico, riding a motorcycle matching the description and carrying a backpack and yellow sack, approached the checkpoint.
• 4. Upon seeing the checkpoint, Suico made a U-turn and fell off his motorcycle.
• 5. He attempted to flee, but police apprehended him and seized his backpack and sack.
• 6. Suico admitted to carrying marijuana and opened the bags, revealing four bundles of marijuana.
• 7. He was arrested, informed of his rights, and taken to the police station.
• 8. An inventory of the seized items was conducted at the police station in the presence of the Municipal Mayor.
• 9. The seized marijuana tested positive in the crime laboratory.
• 10. Suico claimed frame-up, alleging he was robbed by Lumads who planted the marijuana in his bags, and that the police arrived later.

Arguments of the Petitioners

• 1. The warrantless arrest and seizure were illegal.
• 2. Prosecution failed to comply with Section 21 of RA 9165 regarding chain of custody.
• 3. Arresting officers failed to immediately mark the seized items, raising doubt on the corpus delicti.
• 4. Prosecution failed to establish the identity of the seized items as marking was not done in his presence.
• 5. There was a gap in the chain of custody because the officer who received the specimen in the crime lab did not testify.
• 6. Inconsistencies in testimonies of prosecution witnesses cast doubt.
• 7. Defense of frame-up and denial should be given credence.

Arguments of the Respondents

• 1. The arrest and seizure were valid as incidental to a lawful arrest based on probable cause.
• 2. The chain of custody was substantially complied with, preserving the integrity and evidentiary value of the seized marijuana.
• 3. Testimonies of police officers were credible and consistent, outweighing the defense of frame-up and denial.
• 4. Presumption of regularity in the performance of official duties by police officers should prevail.

Issues

• 1. The Supreme Court ruled the arrest was valid because appellant's act of making a sudden U-turn and attempting to flee upon seeing the checkpoint, coupled with the prior tip, provided probable cause for the police officers to believe he was committing a crime.
• 2. The warrantless search and seizure were valid as incidental to a lawful arrest.
• 3. The chain of custody of the seized marijuana was unbroken, and the procedural requirements of Section 21 of RA 9165 were substantially complied with. Marking, inventory, and photography were done at the police station in the presence of the Mayor and later appellant, which was permissible under the law.
• 4. The prosecution presented sufficient evidence to prove beyond reasonable doubt that appellant illegally transported dangerous drugs.
• 5. Appellant's defenses of frame-up and denial were weak and unsubstantiated, and could not overcome the positive testimonies of the police officers who are presumed to have acted in the regular performance of their duties.

Doctrines

• 1. Warrantless Arrest based on Probable Cause: Lawful arrest without a warrant is permissible if there is probable cause to believe the person has committed, is committing, or is about to commit an offense.
• 2. Search Incidental to Lawful Arrest: A warrantless search is valid if it is conducted as an incident to a lawful arrest.
• 3. Chain of Custody: Refers to the duly recorded authorized movements and custody of seized drugs at each stage, from seizure to presentation in court, ensuring integrity and evidentiary value.
• 4. Presumption of Regularity in the Performance of Official Duty: Public officers are presumed to have regularly performed their official duties in the absence of clear and convincing evidence to the contrary.

Key Excerpts

• 1. "Searches and seizures are x x x unreasonable unless authorized by a validly issued search warrant or warrant of arrest."
• 2. "The essential element of the charge of illegal transportation of dangerous drugs is the movement of the dangerous drug from one place to another."
• 3. "[T]estimonies of witnesses need only corroborate each other on important and relevant details concerning the principal occurrence."
• 4. "[N]ot all [the] people who came into contact with the seized drugs are required to testify in court."

Precedents Cited

• 1. People v. Lara: Cited regarding the procedural issue of questioning the legality of arrest after arraignment.
• 2. Veridiano v. People: Cited regarding searches incidental to lawful arrests.
• 3. People v. Cogaed: Cited regarding searches incidental to lawful arrests and probable cause.
• 4. People v. Asislo: Cited regarding the definition of illegal transportation of dangerous drugs.
• 5. People v. Morilla: Cited regarding the definition of "transport" under the Dangerous Drugs Act.
• 6. People v. Mariacos: Cited regarding the sufficiency of actual conveyance for illegal transportation.
• 7. People v. Ygot: Cited regarding the disfavor of defenses like denial and frame-up.
• 8. People v. Pasion: Cited regarding the disfavor of defenses like denial and frame-up.
• 9. People v. Libnao: Cited regarding the need for corroboration among witnesses on principal occurrences.
• 10. People v. Padua: Cited regarding the non-necessity for all persons in the chain of custody to testify.

Statutory and Constitutional Provisions

• 1. Section 5, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002): Defines and penalizes illegal transportation of dangerous drugs.
• 2. Section 21, Article II of Republic Act No. 9165, as amended by RA 10640: Outlines the procedure for custody and disposition of seized dangerous drugs.