### Facts:
This case concerns Jamal Rangaig, Saad Makairing, and Michael Juguilon, who were convicted for violations of RA 9165 (Comprehensive Dangerous Drugs Act of 2002), specifically possession of dangerous drugs and possession of dangerous drugs during a social gathering. The informant tipped the police about a pot session in an abandoned hut, leading to a warrantless arrest and recovery of methamphetamine hydrochloride (shabu). The RTC convicted them, which was affirmed by the Court of Appeals. They appealed, arguing double jeopardy, questioning the warrantless arrest and search, and the compliance with the chain of custody rule.
### Issues:
1. Whether or not the accused-appellants were placed in double jeopardy.
2. Validity of the warrantless arrest and search against accused-appellants.
3. Compliance with the chain of custody rule.
### Court’s Decision:
1. **Double Jeopardy**: The Court found that charging the accused-appellants under both Section 11 (Illegal Possession of Dangerous Drugs) and Section 13 (Possession of Dangerous Drugs during a Social Gathering) of RA 9165 constituted double jeopardy, thereby violating constitutional rights.
2. **Warrantless Arrest and Search**: The Court concluded the warrantless arrest was invalid as it did not comply with the requisites of in flagrante delicto arrest under Rule 113, Section 5 of the Rules of Court. The operation was based solely on an informant’s tip without actual observation of any illegal act by the police.
3. **Chain of Custody**: The Court determined that there were significant lapses in handling the seized dangerous drugs, failing to strictly comply with the chain of custody rule under Section 21 of RA 9165. This failure cast doubts on the integrity and identity of the evidence presented against the accused.
### Doctrine:
The Supreme Court reiterated the doctrine that in warrantless arrests, particularly in drug cases, strict adherence to legal procedures and constitutional rights must be observed. Any lapses in the chain of custody rule can render the seized items inadmissible, and the presumption of regularity in the performance of official duties cannot overcome the constitutional rights of individuals.
### Class Notes:
**Key Elements to Remember**:
– **Double Jeopardy**: Protection against being tried for the same offense twice. Essential for understanding the nuance in charging for drug-related offenses.
– **Warrantless Arrests**: Must strictly comply with conditions under Rule 113, Section 5 of the Rules of Court. Crucial in assessing the legality of police operations.
– **Chain of Custody Rule**: Integral in drug cases to ensure the integrity of seized drugs, with strict compliance required under Section 21 of RA 9165.
### Historical Background:
This case highlights the judiciary’s role in guarding constitutional rights against unreasonable searches and seizures, reasserting the sanctity of these rights amidst aggressive anti-drug campaigns. It emphasizes the balance between upholding law enforcement’s ability to counteract illegal drug activities and ensuring the protection of individual rights.
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