G.R. No. 118653 - People vs. Villegas

Charging and initial proceedings
On January 13, 2004, George Codes Antiquera and Corazon Olivenza Cruz were charged before the RTC of Pasay City (Crim. Case No. 04-0100-CFM) with illegal possession of paraphernalia for dangerous drugs in violation of Section 12, Article II of R.A. 9165.
Cruz jumped bail and was tried in absentia.

Arrest and seizure
On February 11, 2004 at about 4:45 a.m., PO1 Gregorio Recio, PO1 Laurence Cabutihan, P/Insp. Eric Ibon, PO1 Rodelio Rania, and two civilian operatives were on patrol on David Street, Pasay City, when they saw two men flee from house No. 107-C and board a jeep. Suspecting a crime, they approached the house and pushed open a partially ajar door (4–6 inches).
Through the opening, officers purportedly saw Antiquera holding an improvised “tooter” and lighter, and Cruz with aluminum foil and an improvised burner. They entered without a warrant, arrested both, and seized from a wooden jewelry box in the living room: an improvised burner, wok, scissors, 10 sachets with white crystalline substance, improvised scoop, and unused foil strips.
A forensic chemical officer later confirmed the seized paraphernalia tested positive for methamphetamine hydrochloride (“shabu”). Antiquera, however, claimed he was asleep, that officers forced entry and handcuffed him, and that the box was shown to him only at the station.

Lower court decisions
On July 30, 2004, the RTC convicted both respondents, sentencing them to 6 months and 1 day to 2 years and 4 months’ imprisonment, a P10,000 fine, and costs, holding the arrest valid in flagrante delicto under Rule 113, § 5.
On September 21, 2007, the CA affirmed the RTC Decision in full; its denial of reconsideration became final.

Petition before the Supreme Court
Antiquera filed a petition for review on certiorari, contending the warrantless arrest and subsequent search were unlawful, rendering the seized paraphernalia inadmissible and insufficient to sustain his conviction.

Validity of warrantless arrest
Whether the police officers validly arrested Antiquera in flagrante delicto under Section 5(a), Rule 113 of the Rules of Criminal Procedure when they peered through a partially opened door and entered without a warrant.

Admissibility of evidence
Whether the paraphernalia seized during the search incident to arrest are admissible against Antiquera and sufficient to prove illegal possession of drug paraphernalia beyond reasonable doubt.