GR 175700; (July, 2010) (Digest)
G.R. No. 175700 ; July 5, 2010
SALVADOR V. REBELLION, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
Petitioner Salvador V. Rebellion was charged with illegal possession of dangerous drugs. The prosecution evidence established that on July 27, 2000, police officers on patrol chanced upon petitioner and a companion chanting and in the act of exchanging something. Upon the officers’ approach and inquiry, petitioner produced three strips of aluminum foil, which were confiscated. A subsequent search yielded a plastic sachet containing a white crystalline substance. Laboratory tests confirmed the substances were methamphetamine hydrochloride or shabu.
Petitioner denied the charge, claiming he was merely waiting for change in front of a store when suddenly accosted. The Regional Trial Court found him guilty, a decision affirmed by the Court of Appeals. Petitioner now assails his conviction, arguing his warrantless arrest was illegal as he was not committing any crime, rendering the subsequent search and seizure unlawful and the evidence inadmissible.
ISSUE
Whether the Court of Appeals erred in affirming the conviction, given the alleged illegality of the warrantless arrest and the search incident thereto.
RULING
The Supreme Court affirmed the conviction. On the legality of the arrest, the Court ruled that petitioner is estopped from questioning any irregularity. He failed to raise the issue of an illegal arrest or move to quash the information before his arraignment. By entering a plea and actively participating in the trial, he voluntarily submitted to the court’s jurisdiction and waived any perceived defect in his arrest.
Furthermore, the Court clarified that even assuming an illegal arrest occurred, it does not void a subsequent valid conviction based on sufficient evidence and a complaint free from error. The illegality of an arrest is not a ground for setting aside a judgment of conviction. The focus remains on whether the prosecution proved guilt beyond reasonable doubt, which the trial and appellate courts found to be established in this case based on the credible testimonies and evidence presented. The penalty imposed, under the applicable law at the time of the offense, was also correctly applied.