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	GR No. 179475 2009-09-25	PEOPLE v. DANIEL SIBUNGA Y AGTOCA CARPIO MORALES, J.
Finally, the defense of "frame-up" in drug cases is generally frowned upon, for like alibi, it is inherently weak as it is easy to concoct but difficult to prove.[24] For it to prosper, it must be supported by clear and convincing evidence. This appellant failed to do. The presumption that the police officers performed their duties regularly thus remains.[25]