G.R. No. 240447, April 28, 2021
People of the Philippines, Plaintiff-Appellee, vs. Jamal Rangaig y Ampuan, Saad Makairing y Lonto, and Michael Juguilon y Solis, Accused-Appellants.

FACTS

Accused-appellants Jamal Rangaig, Saad Makairing, and Michael Juguilon were charged with violations of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). In Criminal Case No. 2011-0295-D, they were jointly charged with Possession of Dangerous Drugs during a Social Gathering under Section 13. In separate cases (2011-0296-D for Makairing, 2011-0297-D for Juguilon, and 2011-0298-D for Rangaig), each was charged with Possession of Dangerous Drugs under Section 11. The charges stemmed from an incident on June 10, 2011, in Dagupan City. Based on an asset’s tip about an ongoing pot session, police officers conducted a buy-bust operation at an abandoned nipa hut. PO2 Cruz peeked inside, saw three men with two holding aluminum foil, and signaled his team. Upon entry, they arrested Rangaig, Makairing, and Juguilon. A search yielded plastic sachets containing suspected shabu from each accused and drug paraphernalia from a table. The items were marked at the police station. Witness Rebecca Cabading signed the Confiscation Receipt but testified she had no personal knowledge of the operation or how the items were marked and photographed. Chemistry reports confirmed the substances were methamphetamine hydrochloride. The accused denied the allegations, claiming they were arbitrarily arrested while at a store, forced into a vehicle, brought to the police station, and photographed beside a table with items they did not own. The Regional Trial Court convicted them, and the Court of Appeals affirmed the conviction.

ISSUE

The core issue is whether the warrantless arrest of the accused and the subsequent seizure of evidence were valid, and consequently, whether the evidence obtained is admissible to sustain their convictions.

RULING

The Supreme Court REVERSED the Court of Appeals Decision and ACQUITTED accused-appellants. The warrantless arrest was invalid as it did not fall under any recognized exception under Rule 113, Section 5 of the Rules of Court. The arresting officers did not personally witness the accused committing, attempting to commit, or having just committed an offense. Merely seeing them inside a hut with aluminum foil did not constitute in flagrante delicto possession of drugs. The arrest also did not qualify as a valid warrantless arrest under Section 5(b) for offenses committed in the officer’s presence, as the officers had no personal knowledge of facts indicating the accused had just committed an offense. Furthermore, the operation was not a valid buy-bust, as no transaction was consummated. Since the arrest was illegal, the subsequent search and seizure were likewise invalid, rendering the seized items inadmissible as “fruit of the poisonous tree.” The prosecution’s failure to establish a valid warrantless arrest and the broken chain of custody of the seized drugs, highlighted by the witness’s lack of personal knowledge, warranted acquittal on reasonable doubt.