Adoma v. People

Summary

Adoma was arrested during an entrapment operation for stolen laptops when police allegedly found shabu on his person. The Supreme Court reversed his conviction for illegal drug possession, finding the warrantless arrest invalid due to lack of personal knowledge and immediacy required for hot pursuit arrests. Police relied solely on unverified tips and conducted extensive investigation rather than immediate pursuit of a recently committed crime. Additionally, the prosecution failed to establish proper chain of custody as required by Section 21 of RA 9165, with unjustified lapses including absence of photographs, missing required witnesses during inventory, and other procedural violations. The Court emphasized that for valid hot pursuit arrests, officers must have personal knowledge based on observation that a person just committed a crime, coupled with immediacy from crime commission to arrest. The illegal arrest and procedural violations warranted Adoma's acquittal and immediate release.