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    People v. Araneta

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    Stefan Henry P. Rodriguez
    The police received a tip from a confidential informant that Rolando Araneta and Marilou Santos were selling shabu from their home. The police conducted a buy-bust operation where an undercover officer purchased shabu from the suspects. Both suspects were arrested and found in possession of additional drugs. At trial, the suspects claimed they were framed, but were found guilty. They appealed arguing the evidence was inadmissible since their arrest lacked a warrant. However, the court upheld the conviction finding the suspects were caught in flagrante delicto, making the warrantless arrest valid and seizure of the drugs admissible evidence.

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    People v. Araneta

    Uploaded by

    Stefan Henry P. Rodriguez
    874 views1 page
    The police received a tip from a confidential informant that Rolando Araneta and Marilou Santos were selling shabu from their home. The police conducted a buy-bust operation where an undercover officer purchased shabu from the suspects. Both suspects were arrested and found in possession of additional drugs. At trial, the suspects claimed they were framed, but were found guilty. They appealed arguing the evidence was inadmissible since their arrest lacked a warrant. However, the court upheld the conviction finding the suspects were caught in flagrante delicto, making the warrantless arrest valid and seizure of the drugs admissible evidence.

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    The police received a tip from a confidential informant that Rolando Araneta and Marilou Santos were selling shabu from their home. The police conducted a buy-bust operation where an undercover officer purchased shabu from the suspects. Both suspects were arrested and found in possession of additional drugs. At trial, the suspects claimed they were framed, but were found guilty. They appealed arguing the evidence was inadmissible since their arrest lacked a warrant. However, the court upheld the conviction finding the suspects were caught in flagrante delicto, making the warrantless arrest valid and seizure of the drugs admissible evidence.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    874 views1 page

    People v. Araneta

    Uploaded by

    Stefan Henry P. Rodriguez
    The police received a tip from a confidential informant that Rolando Araneta and Marilou Santos were selling shabu from their home. The police conducted a buy-bust operation where an undercover officer purchased shabu from the suspects. Both suspects were arrested and found in possession of additional drugs. At trial, the suspects claimed they were framed, but were found guilty. They appealed arguing the evidence was inadmissible since their arrest lacked a warrant. However, the court upheld the conviction finding the suspects were caught in flagrante delicto, making the warrantless arrest valid and seizure of the drugs admissible evidence.

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    of 1

    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.

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