G.R. No. 113218 ; November 22, 2001
ALEJANDRO TECSON, petitioner, vs. HON. COURT OF APPEALS and PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioner Alejandro Tecson was charged with illegal possession and use of counterfeit US dollar notes under Article 168 of the Revised Penal Code. The prosecution evidence established that, following a prior test-buy operation, a buy-bust team from the Central Bank conducted an operation at a Jollibee restaurant in Manila. A civilian informer introduced undercover agents Pedro Labita and Johnny Marqueta to “Mang Andy,” later identified as Tecson. Upon expressing interest in buying dollars, Tecson produced ten $100 US dollar notes from his wallet. The agents then arrested him. Subsequent examination confirmed the notes were counterfeit. Tecson initialed the notes and signed a receipt and a “Pagpapatunay” during investigation.
The defense presented a different version. Tecson claimed he was at the restaurant to meet a friend’s wife regarding an insurance matter. Upon receiving a sealed envelope, he was immediately arrested, handcuffed, and blindfolded. He alleged the counterfeit notes were planted and that he was tortured into initialing and signing the documents. He denied any knowledge or possession of the fake currency.

ISSUE

The core issues were whether the prosecution evidence was sufficient and admissible to support Tecson’s conviction, and whether his warrantless arrest and the seizure of evidence were lawful.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the validity of the warrantless arrest and the admissibility of the seized evidence. The Court ruled that the arrest was lawful as it was effected during a buy-bust operation where Tecson was caught in flagrante delicto—in the act of possessing and offering to sell counterfeit US dollars. A warrantless arrest is permissible under Rule 113, Section 5(a) of the Rules of Court when the person is apprehended while committing a crime. Consequently, the counterfeit notes seized from him during this valid arrest were admissible as evidence.
The Court found the prosecution’s version credible and consistent. The defense of frame-up was rejected as a self-serving claim unsupported by evidence and viewed with disfavor in buy-bust cases. The legal presumption that public officers regularly perform their duties was not overturned. While any custodial statements obtained without counsel were disregarded, the conviction was firmly based on the physical evidence (the counterfeit notes) and the eyewitness accounts of the in flagrante arrest, which were legally obtained. Thus, all elements of illegal possession and use of counterfeit notes were proven beyond reasonable doubt.