G.R. No. 201363 - People vs. Villareal y Lualhati

On December 25, 2006 at around 11:30 AM along 5th Avenue, Caloocan City, PO3 Renato de Leon, while driving his motorcycle, observed appellant Nazareno Villareal y Lualhati holding and examining a small plastic sachet allegedly containing “shabu.”
PO3 de Leon recognized appellant from prior arrests, alighted from his motorcycle, and approached him. Appellant attempted to flee but was apprehended with the help of a tricycle driver. The police officer seized the sachet, handcuffed appellant, brought him to the 9th Avenue Police Station, and marked the evidence “RZL/NV 12-25-06.”

Investigator PO2 Randulfo Hipolito took custody of the marked sachet, executed an acknowledgment receipt, and prepared a request letter for laboratory analysis.
The evidence and request were delivered to the PNP Crime Laboratory, received by PSI Albert Arturo, and tested positive for 0.03 gram of methylamphetamine hydrochloride.

Appellant was charged under Section 11, Article II of RA 9165 for illegal possession of dangerous drugs. He pleaded not guilty.
In his defense, appellant denied possession, claimed mistaken identity, alleged robbery of P1,000 by PO3 de Leon, physical mauling, and coercion into a false inquest confession.

RTC Decision (Dec. 11, 2007): Convicted appellant, applying the plain view doctrine, finding credible testimony and an unbroken chain of custody; sentenced to 12 years and one day to 14 years and eight months’ imprisonment and a ₱300,000 fine.
CA Decision (May 25, 2011): Affirmed conviction, held arrest lawful in flagrante delicto under Rule 113, Section 5, citing suspicious conduct, past criminal record, flight, and intact chain of custody.

Whether the Court of Appeals erred in affirming the conviction based on a purportedly lawful warrantless arrest under Section 5, Rule 113 of the Revised Rules of Criminal Procedure.