### Facts:
On July 31, 2000, Salvador V. Rebellion was charged with a violation of Section 16, Article III of Republic Act No. 6425 (the Dangerous Drugs Act of 1972, as amended) for illegally possessing Methamphetamine Hydrochloride, commonly known as “shabu”. The charge stemmed from an incident on July 27, 2000, in Mandaluyong City, Philippines, where Rebellion was arrested alongside another individual, Clarito Yanson. The arrest was made by members of the Mayor’s Action Command (MAC) of Mandaluyong City during a routine patrol. They observed Rebellion and Yanson exchanging an item that spurred suspicion, leading to their confrontation and arrest. Recovered from Rebellion were three strips of aluminum foil and a plastic sachet containing a white crystalline substance that later tested positive for “shabu”.
During the trial, Rebellion pleaded not guilty and claimed he was merely waiting for change from a transaction at a store when apprehended. The Regional Trial Court (RTC), however, found him guilty, sentencing him to an indeterminate penalty ranging from six months of arresto mayor to two years and four months of prision correccional. This decision was subsequently upheld by the Court of Appeals (CA), although with a slight modification in the sentencing.
### Issues:
The core legal issue raised in the Supreme Court was the legality of Rebellion’s warrantless arrest. Rebellion contended that he was not committing or attempting to commit an offense at the time of his arrest, rendering the subsequent search and seizure of his person unlawful and the evidence obtained thereby inadmissible.
### Court’s Decision:
The Supreme Court affirmed the rulings of the lower courts, holding that Rebellion’s warrantless arrest was justified under the circumstances, which constituted a valid instance of an arrest in flagrante delicto. The Court determined that the MAC officers had observed Rebellion and Yanson in the act of exchanging what they reasonably suspected to be illegal drugs, which provided a valid basis for the warrantless arrest and subsequent search and seizure of the “shabu”. Rebellion’s conviction was thus upheld on the grounds that:
– There was no timely challenge to the legality of the arrest, which constituted a waiver of any objection thereto;
– The arrest fell within the exceptions to the requirement for a warrant as provided by the Rules of Court, specifically an arrest of a person committing an offense in the presence of the arresting officer;
– The evidence of the offense was properly admitted, being the consequence of a lawful arrest.
### Doctrine:
This case reaffirms the doctrine that a warrantless arrest is considered lawful if the person being arrested is caught in the act of committing an offense. Additionally, it underscores the principle that any objection to the legality of an arrest must be made before arraignment, or else it is deemed waived.
### Class Notes:
– **Illegal Possession of Dangerous Drugs:** The elements are (1) possession by the accused of an item or object identified to be a prohibited or dangerous drug, (2) such possession is not authorized by law, and (3) the accused has knowledge of the possession.
– **Warrantless Arrest:** Valid under Rule 113, Section 5 of the Rules of Court when the person to be arrested has committed, is actually committing, or is attempting to commit an offense in the presence of the arresting officer.
– **Doctrine of Waiver:** Failure to challenge the legality of an arrest before arraignment constitutes a waiver of any such challenge.
### Historical Background:
This case is set against the backdrop of the Philippine Government’s stringent policies against illegal drugs, highlighting the legal frameworks around warrantless arrests and the possession of dangerous drugs, as governed by Republic Act No. 6425, as amended by Republic Act No. 7659, and further by Republic Act No. 9165, known as the Comprehensive Dangerous Drugs Act of 2002.
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