GR 88401; (February, 1991) (Digest)
G.R. No. 88401 ; February 19, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CESAR SEGWABEN y CARLIN, accused-appellant.
FACTS
Accused-appellant Cesar Segwaben was convicted by the Regional Trial Court of Pasig for violating the Dangerous Drugs Act. The information alleged that on June 30, 1988, in Pasig, Metro Manila, he unlawfully delivered 78.06 grams of hashish oil to Sgt. Marino Gumabay. The prosecution evidence established that a buy-bust operation was conducted by Narcotics Command agents based on a tip. Sgt. Gumabay acted as poseur-buyer and negotiated a purchase. The transaction, initially set in a canteen, was moved to a parking lot where Segwaben handed over the hashish oil. Upon receiving the pre-arranged signal, arresting officers moved in, but Segwaben grabbed and threw the package, which was later recovered.
ISSUE
The core issue is whether the trial court erred in convicting the accused based on the evidence presented and in ruling that his warrantless arrest was valid.
RULING
The Supreme Court affirmed the conviction. The legal logic centered on the credibility of the prosecution witnesses and the validity of the warrantless arrest. The Court upheld the trial court’s assessment, giving full credence to the testimonies of the law enforcement officers. It emphasized the presumption of regularity in the performance of official duties, which was not overturned by any convincing proof of ill motive, as the appellant himself admitted having no prior quarrel with the arresting officers. Regarding the arrest, the Court ruled it was lawful under Rule 113, Section 5(a) of the Rules of Court. A buy-bust operation is a valid form of entrapment where the accused is caught in flagrante delicto—in the very act of committing the offense. Consequently, the police were not only authorized but duty-bound to arrest the appellant without a warrant. The Court also noted that the appellant’s subsequent motion to plead guilty to a lesser offense, though improperly timed after conviction, further corroborated the finding of guilt. Thus, the evidence proved his guilt beyond reasonable doubt.