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

The Supreme Court ruled that the warrantless arrest of Nazareno Villareal y Lualhati for alleged shabu possession was unlawful, leading to his acquittal due to inadmissible evidence. The Court found that the arresting officer could not have reasonably identified the substance from a distance and that the appellant's flight did not constitute conclusive evidence of guilt. Consequently, the Court reversed the lower court's decision and ordered the immediate release of the appellant unless detained for another lawful cause.

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64 views3 pages

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

The Supreme Court ruled that the warrantless arrest of Nazareno Villareal y Lualhati for alleged shabu possession was unlawful, leading to his acquittal due to inadmissible evidence. The Court found that the arresting officer could not have reasonably identified the substance from a distance and that the appellant's flight did not constitute conclusive evidence of guilt. Consequently, the Court reversed the lower court's decision and ordered the immediate release of the appellant unless detained for another lawful cause.

Uploaded by

Cherry Lynn Aragon
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd

Title

People vs. Villareal y Lualhati

Case Decision Date


G.R. No. 201363 Mar 18, 2013

PO3 de Leon arrested appellant for alleged shabu possession; Supreme Court
ruled warrantless arrest unlawful, acquitting appellant due to inadmissible
evidence.

Jur.ph - Case Digest (G.R. No. 201363)


Legal Reasoning Model

Facts:
Incident Details:

On December 25, 2006, at around 11:30 AM, PO3 Renato de Leon, a member of
the Station Anti-Illegal Drugs-Special Operation Unit (SAID-SOU) in Caloocan
City, was driving his motorcycle along 5th Avenue.
From a distance of 8 to 10 meters, PO3 de Leon saw appellant Nazareno Villareal
y Lualhati holding and scrutinizing a plastic sachet of shabu.
PO3 de Leon recognized appellant as someone he had previously arrested for
illegal drug possession.

Arrest and Seizure:

Upon seeing PO3 de Leon, appellant attempted to escape but was apprehended
with the help of a tricycle driver.
PO3 de Leon confiscated the plastic sachet of shabu from appellant, marked it
with "RZL/NV 12-25-06," and brought appellant to the 9th Avenue Police Station.
The seized item was later turned over to PO2 Randulfo Hipolito, who prepared a
request for laboratory examination.
The Philippine National Police (PNP) Crime Laboratory confirmed that the
substance in the sachet was 0.03 grams of methylamphetamine hydrochloride
(shabu).

Charges:

Appellant was charged with illegal possession of dangerous drugs under Section
11, Article II of Republic Act No. 9165 (RA 9165).

Defense:
Appellant denied the allegations, claiming that PO3 de Leon robbed him of his
wallet containing P1,000.00 and that he was mauled by detainees and police
officers.
He alleged that he was forced to answer questions about a stolen cellphone and
was subjected to physical abuse.

Issue:
(Unlock)

Ruling:
(Unlock)

Ratio:

1. Warrantless Arrest Requirements:

For a warrantless arrest to be valid under Section 5(a), Rule 113, the arresting
officer must witness the suspect committing, attempting to commit, or
having just committed a crime.
The Court found that PO3 de Leon could not have reasonably identified the
substance in appellant's hand as shabu from a distance of 8 to 10 meters
while driving a motorcycle.
Appellant's actions (walking and holding something) were not inherently
criminal and did not justify a warrantless arrest.

2. Personal Knowledge of the Arresting Officer:

The Court emphasized that "personal knowledge" under Section 5(b)


requires the arresting officer to know for a fact that a crime has just been
committed.
PO3 de Leon's knowledge of appellant's previous arrests did not constitute
personal knowledge of a crime being committed at the time of arrest.

3. Flight as Evidence of Guilt:

The Court ruled that appellant's attempt to flee was not conclusive evidence
of guilt. Flight alone, without other corroborating circumstances, is
insufficient to establish probable cause.

4. Fruit of the Poisonous Tree Doctrine:

Since the arrest was unlawful, the seized shabu was inadmissible as
evidence. The confiscated item, being the corpus delicti of the crime, could
not be used to convict appellant.

5. Acquittal:

The Court acquitted appellant due to the prosecution's failure to establish the
legality of the arrest and the admissibility of the evidence.

Conclusion:
The Supreme Court reversed the CA's decision, acquitted appellant Nazareno
Villareal y Lualhati, and ordered his immediate release unless detained for another
lawful cause.

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