PEOPLE v.

ARANETA
October 20, 2010 | Mendoza, J. | Petition for Review on Certiorari | Arrests: Warrantless Arrests In Flagrante Delicto
PETITIONER: People of the Philippines
RESPONDENT: Rolando Araneta and Marilou Santos
SUMMARY: Upon receipt of condifdential information, police officers formed an entrapment unit against the live-in partners
Rolando Araneta and Marilou Santos. According to the information, the two are engaged in selling crystalline substance belived to
be metampethamine hydrochloride (shabu). The buy-bust operation was successful and yielded 9 plastic sachets of shabu and one
plastic sachet of marijuana. The respondents were found guilty of selling shabu. Also, Rolando was convicted of illegal possession
of 8 sachets of shabu and one sachet of marijuana. They now contend that the items seized are not admissible as evidence for being
derived from unlawful arrest. The Court ruled that they were caught in fladrante delicto; hence, the subsequent seizure was valid.
DOCTRINE: A search warrant or warrant of arrest is not needed in a buy-bust operation. The accused caught in such operation is
caught in flagrante delicto. This is an admissible method of capturing offenders as the criminal intent originates from the offender
and not from law enforcement officers. Hence, the search and seizure subsequent to the arrest is admissible as evidence.
FACTS:
1. The police officers received, between 3:00 to 3:30 in
the morning, an information of an alleged peddling of
illegal drugs from a confidential informant. The
peddlers were Rolando and Marilou.
2. SPO4 Lara formed a team with SPO2 Zigapan as
team leader and PO2 Damasco as poseur-buyer.
SPO4 Zigapan gave PO2 Damasco the P100 bill
marked money to be used for the operation.
3. The team arrived around 4:00 am on the target place
where they saw the respondents standing outside their
house. The informant talked to the respondents and
introduced PO2 Damasco as buyer.
4. Rolando went inside the house to get the drugs to be
sold. PO2 Damasco handed over the marked bill to
Marilou. When Rolando went outside their house, he
gave a plastic sachet containing the crystalline
substance. Upon receipt, PO2 Damasco examined it.
5. PO2 made the signal and the respondents were
promptly apprehended. Aside from the marked
money and the plastic sachet containing shabu sold to
PO2 Damasco, Rolando was also found to have 8
sachets of shabu and one sachet of marijuana.
6. On trial, respondents posed the defense of frame-up,
planting evidence, forcible entry and extortion.
7. The found guilty by the RTC of selling illegal or
prohibited drugs. Rolando is also found guilty of
possessing shabu and marijuana. The CA affirmed.
8. They now contend that the evidence should not be
admissible for there is not valid warrant of arrest and
search warrant. Also, they contend that there is
failure on the part of the officers to observe proper
custody of dangerous drugs. As such, the prosecution
was not able to establish that the drugs presented
were actually the drugs seized.
ISSUE/S:
1. WON illegal sale of dangerous drugs is established YES
2. WON the defense of denial and alibi can be admitted - NO

3. WON the seized items were admissible - YES

RULING: CA decision is AFFIRMED.
RATIO:
1. The prosecution was able to establish all the elements
required in the prosecution for illegal sale of dangerous
drugs, namely: 1) the identity of the buyer and seller; 2)
the identity of the object of the sale and the consideration;
and 3) the delivery of the thing sold upon payment. Malou
gave the marked money to Botong who, in turn, gave
Malou a plastic sachet containing a white crystalline
substance. The plastic sachet was then handed over to PO2
Damasco who examined it and immediately gave the prearranged signal to arrest the accused. During the arrest, the
marked money was recovered from Rolando and so were
several other plastic sachets containing white crystalline
substances together with a plastic sachet containing
marijuana. The testimony of PO2 Damasco was clear,
consistent and convincing.
2. Aside from their bare allegations, the accused had nothing
more to show that the apprehending police officers did not
properly perform their duties or that they had ill motives
against them. They failed to substantiate their argument
that they were framed-up for extortion purposes.
3. The seized items were admissible. A search warrant or
warrant of arrest was not needed because it was a buy-bust
operation and the accused were caught in flagrante delicto
in possession of, and selling, dangerous drugs to the
poseur-buyer. It was legal for the buy-bust team to arrest,
and search, them on the spot because a buy-bust operation
is a justifiable mode of apprehending drug pushers. A buybust operation is a form of entrapment whereby ways and
means are resorted to for the purpose of trapping and
capturing lawbreakers in the execution of their criminal
plan. In this jurisdiction, the operation is legal and an
effective method of apprehending drug peddlers, provided
due regard to constitutional and legal safeguards is
undertaken.