G.R. No. 229380. June 06, 2018.
LENIZA REYES Y CAPISTRANO, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

The prosecution alleged that on November 6, 2012, police officers in Cardona, Rizal, acting on a tip from teenagers, encountered petitioner Leniza Reyes. The officers, noting she matched the description provided (long hair, dragon tattoo, smelling of liquor), asked if she had bought shabu. Reyes allegedly responded, “Di ba bawal kayong magkapkap ng babae?” then turned, pulled a plastic sachet from her breast area, and held it. PO1 Jefferson Monteras confiscated the sachet, marked it, and after inventory and photography at the station with a barangay official present, had it examined. The substance tested positive for 0.04 gram of methamphetamine hydrochloride. Reyes presented a different version, claiming the arrest occurred a day earlier during an extortion attempt where police demanded money after she was illegally apprehended without any drugs being found.

ISSUE

Whether or not Reyes’s conviction for Illegal Possession of Dangerous Drugs under Section 11, Article II of Republic Act No. 9165 should be upheld.

RULING

No. The Supreme Court acquitted Reyes. The conviction was overturned because the search and seizure leading to the discovery of the drugs were unconstitutional, rendering the evidence inadmissible. The police had no warrant for Reyes’s arrest or search. The prosecution failed to prove the arrest fell under a valid warrantless arrest exception. For a valid in flagrante delicto arrest under Rule 113, Section 5(a) of the Rules of Court, the person must be caught in the act of committing an offense. Here, the police officers merely approached Reyes based on an unverified tip and her matching a general description. Her alleged act of pulling out the sachet only occurred after the police accosted her. The Court ruled this was a mere “stop-and-frisk” situation that did not justify a full warrantless arrest and search. Since the arrest was illegal, the subsequent search and seizure of the drug evidence were likewise illegal, being the “fruit of the poisonous tree.” Consequently, the drug sachet was inadmissible as evidence. With the corpus delicti rendered inadmissible, Reyes’s guilt could not be proven beyond reasonable doubt. The Court emphasized that while the war on drugs is paramount, it must be waged within the bounds of law, with strict adherence to constitutional rights against unreasonable searches and seizures.