Case Summary (G.R. No. 198694)
Factual Background and Arrest
On December 29, 2007, around 9:15 p.m., police officers on patrol in Balingkit Street, Malate, Manila, responded to a man shouting what was characterized as potentially disturbing words. The man, identified as Ramon, allegedly violated Section 844 of the Revised Ordinance of the City of Manila for breach of peace. He was apprehended without a warrant, and during a body search incident to arrest, officers recovered a small plastic sachet containing 0.173 grams of a white crystalline substance later identified by a forensic chemist as shabu (methylamphetamine hydrochloride). Ramon was charged with illegal possession of dangerous drugs based on this seizure.
Petitioner's Defense and Allegations
Ramon denied the charges, contesting the legality of his arrest and search. He contended that he was accosted by a man in civilian clothes who identified himself as a police officer, confronted him without probable cause, and handcuffed him without lawful justification. He alleged that PO2 Soque demanded P20,000.00 from him in exchange for his release, which his wife could not provide, leading to formal inquest proceedings. Ramon claimed the arrest lacked lawful basis and was essentially a result of police misconduct and extortion.
RTC Decision and Sentence
The Regional Trial Court (RTC), Branch 2, Manila, found Ramon guilty, affirming that all elements of possession of dangerous drugs were present: illegal possession, the nature of the substance involved, and conscious control over the drug. The RTC also ruled that the warrantless arrest was legal as Ramon’s conduct constituted a breach of peace under the Manila City Ordinance, which justified the search. He was sentenced to twelve years and one day to seventeen years and four months imprisonment and fined P300,000.
Court of Appeals Ruling
The Court of Appeals (CA) upheld the RTC's ruling, affirming that: (1) the elements of possession of dangerous drugs were sufficiently established; (2) the warrantless arrest and search were lawful and valid as the arrest was made for a breach of peace committed in the presence of police officers; (3) the chain of custody of the seized drugs was properly maintained; and (4) Ramon's extortion claims were unsubstantiated and failed to overcome the presumption of regularity in police conduct.
Issue on Appeal
The sole issue before the Supreme Court was whether the CA erred in affirming Ramon's conviction for possession of dangerous drugs based on the legality of his warrantless arrest and subsequent search.
Supreme Court’s Legal Analysis: Constitutional Protections and Warrantless Arrest
Invoking Section 2, Article III, of the 1987 Philippine Constitution, the Court emphasized the constitutional guarantee against unreasonable searches and seizures, which mandates that no arrest or search shall be made without probable cause and a valid warrant except under certain exceptions. Additionally, Section 3(2), Article III prohibits the admission of evidence obtained in violation of these rights through the exclusionary rule.
The Court acknowledged known exceptions to the warrant requirement, including searches and seizures incident to lawful arrests. A lawful warrantless arrest requires that the person be caught in flagrante delicto, with probable cause based on the officer’s reasonable ground of suspicion supported by circumstances sufficient to convince a prudent person of the offense committed.
Examination of Probable Cause and the Ordinance Violation
The Court examined Section 844 of the Manila City Ordinance, which penalizes acts that disturb the peace, including riots, affrays, and abusive language inciting a breach of the peace in public places. The Court noted the essential element for such violation is actual disturbance of the public tranquility.
Testimony from PO2 Soque described detecting shouting by Ramon and immediate apprehension for breach of peace. However, the Court found significant inconsistencies and inadequacies in this account. The shouting occurred in a busy area where many people were talking; the words shouted, “Putang ina mo! Limang daan na ba ito?” did not constitute slanderous, threatening, or abusive language sufficient to disturb the peace. No
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Case Background and Lower Court Decisions
- Petitioner Ramon Martinez y Goco (Ramon) was charged with possession of dangerous drugs under Section 11(3), Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
- Incident occurred on December 29, 2007 at approximately 9:15 PM along Balingkit Street, Malate, Manila.
- Police officers PO2 Roberto Soque, PO2 Alejandro Cepe, and PO3 Edilberto Zeta, stationed at the Anti-Illegal Drugs Section of Malate Police Station 9, apprehended Ramon after hearing him shouting allegedly abusive language.
- Ramon was arrested purportedly for violating Section 844 of the Revised Ordinance of the City of Manila (breach of peace).
- Upon arrest, a plastic sachet containing 0.173 gram of white crystalline substance (later found positive for methylamphetamine hydrochloride—shabu) was seized from Ramon.
- The confiscated substance and specimen were sent to the PNP Crime Laboratory for forensic examination.
- Ramon was charged via Information dated January 3, 2008, for unlawful possession of dangerous drugs.
- Ramon denied the charges and claimed he was unlawfully apprehended by a man in civilian clothes who later identified himself as a police officer.
- Defense alleged an extortion attempt of P20,000 by PO2 Soque in exchange for Ramon's release.
- The Regional Trial Court (RTC), Branch 2, Manila, convicted Ramon on April 30, 2009, finding the warrantless arrest lawful and the evidence credible.
- Ramon appealed to the Court of Appeals (CA), which upheld the RTC decision in a June 30, 2011 ruling, reaffirming the evidence and validity of arrest and search.
- The CA also dismissed Ramon's extortion claims for lack of evidence overriding the presumption of regularity in police officers’ duties.
Central Legal Issue
- Whether the Court of Appeals erred in affirming the RTC’s conviction of Ramon for possession of dangerous drugs, particularly regarding the legality of the warrantless arrest and consequent search.
Supreme Court Ruling and Reasoning
- The petition was granted, reversing and setting aside the CA decision and acquitting Ramon.
- Emphasized the c