(CPR) People Vs Martinez, GR No 191366, 13 December 2010 Case Digest

TITLE: People of the Philippines v. Arnold Martinez, et al., G.R. No.
191366
DATE: December 13, 2010
PONENTE: Justice Mendoza
HEADING: Procedure in executing a warrant of arrest
APPELLEE: People of the Philippines
APPELLANT: Arnold Martinez, Edgar Dizon, Rezin Martinez, and Rafael Gonzales
FACTS:
• The appellants were arrested by the police officers based on a tip from a concerned
citizen that a pot session was going on in the house of Gonzales.
• The police officers entered the house without a warrant and seized several items
containing shabu residue.
• The appellants were charged with possession of dangerous drugs during parties,
social gatherings or meetings under R.A. No. 9165.
• The RTC and the CA convicted the appellants and sentenced them to life
imprisonment.
PROCEDURAL HISTORY OF THE CASE
INFORMATION FILED:
That on or about the 2nd day of September 2006, in the City of Dagupan, Philippines,
and within the jurisdiction of this Honorable Court, the above-named accused, ARNOLD
MARTINEZ y ANGELES, EDGAR DIZON y FERRER, REZIN MARTINEZ y CAROLINO,
ROLAND DORIA y DIAZ and RAFAEL GONZALES y CUNANAN, without authority of law,
confederating together, acting jointly and helping one another, did then and there
wilfully, unlawfully and criminally, sniff and possess dangerous drugs (shabu residues)
contained in empty plastic sachets and rolled aluminum foil, during a party, or at a
social gathering or meeting, or in the proximate company of at least two (2) person [s].
NATURE OF THE CASE: Appeal from the decision of the CA affirming the conviction of
the appellants by the RTC.
PROCEDURAL HISTORY
 The RTC found the appellants guilty of the crime charged and sentenced them to
life imprisonment and a fine of P500,000.00 each.
 The appellants appealed to the CA, which affirmed the RTC’s decision.
 The appellants filed a notice of appeal to the Supreme Court, which gave due
course to the appeal.
ISSUES OF THE CASE
 Whether the arrest of the appellants was lawful.
 Whether the seized items were admissible as evidence.
 Whether the chain of custody of the seized items was properly established.
ARGUMENTS OF PETITIONERS
 The appellants argued that their arrest was illegal because the police officers had
no warrant and no probable cause to enter the house of Gonzales.
 The appellants also argued that the seized items were inadmissible as evidence
because they were obtained in violation of their constitutional right against
unreasonable searches and seizures.
 The appellants further argued that the chain of custody of the seized items was
questionable because the authorities failed to comply with the requirements of
R.A. No. 9165 and its implementing rules.
ARGUMENTS OF RESPONDENTS
 The appellee argued that the arrest of the appellants was valid because they
were caught in flagrante delicto of possessing dangerous drugs.
 The appellee also argued that the seized items were admissible as evidence
because they were seized in plain view and their integrity and evidentiary value
were preserved.
 The appellee further argued that the chain of custody of the seized items was
sufficiently established because there was no showing of any tampering or
substitution of the evidence.
HELD/RATIO:
 The Supreme Court held that the arrest of the appellants was illegal because the
police officers had no personal knowledge or reasonable ground to believe that
the appellants had committed, were committing, or were about to commit a
crime. The tip from the concerned citizen was not sufficient probable cause to
justify a warrantless arrest.
 The Supreme Court also held that the seized items were inadmissible as evidence
because they were obtained as a result of an illegal arrest. The plain view
doctrine did not apply because there was no valid intrusion by the police officers.
The evidence was not inadvertently discovered but intentionally searched for.
 The Supreme Court further held that the chain of custody of the seized items
was not properly established because there were numerous lapses and
irregularities in the handling, marking, inventory, and testing of the evidence.
The prosecution failed to prove the identity of the corpus delicti with moral
certainty.
DISPOSITION: WHEREFORE, the Decision of the Court of Appeals dated August 7,
2009 in CA-G.R. HC No. 03269 is REVERSED and SET ASIDE. Accused-appellants Arnold
Martinez y Angeles, Edgar Dizon y Ferrer, Rezin Martinez y Carolino, and Rafael
Gonzales y Cunanan are hereby ACQUITTED of the crime charged on the ground of
reasonable doubt, and are ordered immediately RELEASED from detention, unless they
are confined for any other lawful cause. The Director of the Bureau of Corrections is
DIRECTED to implement this Decision and to report to this Court the action taken
hereon within five (5) days from receipt. SO ORDERED.

(CPR) People Vs Martinez, GR No 191366, 13 December 2010 Case Digest

Uploaded by

Copyright:

Available Formats

(CPR) People Vs Martinez, GR No 191366, 13 December 2010 Case Digest

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

(CPR) People Vs Martinez, GR No 191366, 13 December 2010 Case Digest

Uploaded by

Copyright:

Available Formats

TITLE: People of the Philippines v. Arnold Martinez, et al., G.R. No.

You might also like