Marinduque v. People

Summary

The Supreme Court granted petitioner's petition for review and acquitted him of illegal possession of dangerous drugs under R.A. 9165. While the Court found the warrantless arrest valid under the in flagrante delicto rule when shabu fell from petitioner's pocket during a checkpoint, it ruled the prosecution failed to prove guilt beyond reasonable doubt due to fatal lapses in the chain of custody. Critical deficiencies included: absence of required photographs of seized drugs, unexplained variance in evidence markings, inadequate testimony from the forensic chemist regarding post-examination handling, and complete lack of testimony about storage and preservation before trial. The Court emphasized that in drug cases involving miniscule amounts, strict compliance with chain of custody requirements is crucial to preserve the integrity of the corpus delicti. The presumption of regularity in police performance cannot override the constitutional presumption of innocence when evidence raises reasonable doubt.