G.R. No. 93239. March 18, 1991 (Case Brief / Digest)

### Title: People of the Philippines v. Edison Sucro

### Facts:
On March 21, 1989, in Kalibo, Aklan, Edison Sucro was caught selling marijuana. Following a surveillance operation instructed by P/Lt. Vicente Seraspi, Jr. due to reports of Sucro’s drug activities, Pat. Roy Fulgencio monitored the accused. Fulgencio witnessed Sucro engage in selling marijuana from a chapel to various customers, including one Aldie Borromeo and Ronnie Macabante. Based on Fulgencio’s observations relayed to Seraspi, a police operation led to the apprehension of Sucro and the recovery of marijuana from him and Macabante. Sucro’s subsequent trial resulted in a conviction for selling prohibited drugs under Section 4, Article II of the Dangerous Drugs Act, sentencing him to life imprisonment and a fine of P20,000.

Sucro appealed the conviction, arguing the illegality of the warrantless arrest and the admission of the seized drugs as evidence. The procedural journey reached the Supreme Court, where the defense challenged the lower court’s admission of drug evidence (Exhibits “E” – “E-4”) and the validity of Sucro’s guilt under the pertinent law.

### Issues:
1. Whether the warrantless arrest of Sucro was lawful;
2. If the evidence obtained during this arrest was admissible;
3. The credibility of witness testimony post-arrest, specifically Ronnie Macabante’s testimony;
4. The validity of Sucro’s defense of alibi against the prosecution’s evidence.

### Court’s Decision:
The Supreme Court affirmed the lower court’s decision, ruling that:

1. The warrantless arrest was lawful under Section 5, Rule 113 of the Rules on Criminal Procedure due to the crime being committed in the presence of law enforcement, thus rendering the subsequent search and seizure valid.
2. The evidence obtained from Sucro’s lawful arrest was admissible, as it directly connected him to the crime of selling marijuana.
3. Testimonies of witnesses (including Ronnie Macabante) involved in or observing the drug transaction were credible and supported by the regular performance of duty by law enforcement officers.
4. Sucro’s alibi was insufficient to overcome the positive identification of his involvement in drug selling, and his presence in the area was admitted, contradicting his claim of being elsewhere.

### Doctrine:
The Supreme Court reiterated the principle that warrantless arrests can be lawful if the arrestee is seen committing, is about to commit, or has just committed an offense (Section 5, Rule 113 of the Rules on Criminal Procedure). Additionally, the decision reinforced that credibility is given to the trial court’s assessment of witness testimony, especially when corroborated by other evidence and official duties of law enforcement.

### Class Notes:
– **Warrantless Arrest**: Lawful under certain conditions such as the crime occurring in the presence of an officer (Section 5, Rule 113, Rules on Criminal Procedure).
– **Search Incident to Lawful Arrest**: Items connected to the crime can be seized without a warrant if the arrest itself is lawful.
– **Evidence Admissibility**: Evidence obtained from a lawful arrest is considered admissible in court.
– **Witness Testimony**: The credibility of a witness is established based on the demeanor observed by the trial court and is generally upheld on appeal unless significant oversight is demonstrated.
– **Defense of Alibi**: Fails against positive identification and credible witness testimony tying the defendant to the crime.
– **Probable Cause for Warrantless Action**: Exists based on reasonable grounds or intelligence reports indicating involvement in a crime, leading to lawful police action.

### Historical Background:
The case was decided in the context of the Philippines’ ongoing battle against illegal drugs, where law enforcement is often challenged by the imperatives of rapidly responding to ongoing criminal activities and the judicial mandate to respect the due process rights of suspects. It illustrates the balancing act courts perform in assessing the legality of police actions against the backdrop of protecting society from prohibited substances.


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