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#### Facts:
1. On November 1995, PNP Narcom agents received tips about “Jun” (Florencio Doria) engaging in illegal drug activities in Mandaluyong City.
2. A buy-bust operation was planned, with a meeting scheduled for December 5, 1995.
3. On December 5, 6:00 AM, at PNP Headquarters in Quezon City, the buy-bust team (Team Alpha) prepared, using P1,600 in marked bills.
4. PO3 Manlangit acted as the poseur-buyer, with “Jun” handing over a kilo of marijuana. When Doria was arrested, the marked bills were not found on him.
5. Doria implicated Gaddao (coded as “Neneth”) as holding the marked money.
6. The buy-bust team, led by Doria, entered Gaddao’s house where they saw marijuana under a table. Gaddao was arrested, and marked bills were found on her.
7. At trial, Doria and Gaddao claimed innocence, arguing for procedural violations.
8. The trial court convicted both, emphasizing an organized crime group, and sentenced them to death, prompting an automatic review by the Supreme Court.
#### Issues:
1. **Validity of Doria’s Buy-Bust Operation:** Whether the buy-bust operation constituted entrapment or enticement.
2. **Legitimacy of Gaddao’s Warrantless Arrest:** If the police followed procedural rules for the warrantless search and arrest.
3. **Applicability of the “Plain View” Doctrine:** If the discovery and seizure of marijuana were proper under the “plain view” exception.
#### Court’s Decision:
1. **Validity of Buy-Bust Operation:**
– The Court upheld the buy-bust operation, affirming it wasn’t inducement but a legitimate entrapment. Doria was predisposed to commit the crime.
2. **Legitimacy of Warrantless Arrest:**
– The Court ruled Gaddao’s arrest was invalid. The police did not witness her committing a crime, nor did they have probable cause.
– Her arrest based on mere suspicion without direct involvement in the drug transaction was illegal.
3. **Plain View Doctrine Application:**
– The application of the plain view doctrine was incorrect as the marijuana wasn’t immediately apparent as contraband without closer inspection.
– Consequently, the seizure of the marijuana from Gaddao’s house was deemed unconstitutional, invalidating the evidence.
#### Doctrines:
– **Entrapment vs. Inducement:** Entrapment is lawful when it merely provides an opportunity for a willing suspect to commit a crime; inducement or instigation, which plants the idea of the crime, is not.
– **Plain View Doctrine:** Seizure without a warrant is valid only if the evidence is immediately recognizable as contraband or evidence of a crime without further search.
– **Warrantless Arrest:** Only valid under (a) in flagrante delicto (caught in the act), (b) hot pursuit with probable cause, or (c) direct escape from custody.
#### Class Notes:
1. **Entrapment Defenses:**
– Entrapment: Crime initiated by the defendant, valid police decoys.
– Inducement: Crime initiated by officers, illegal.
2. **Plain View Doctrine:**
– Valid if the incriminating nature is immediately apparent without further search.
– Plain view inside a closed container generally needs broader support to be valid.
3. **Warrantless Arrests:**
– In flagrante delicto: Direct view of the crime.
– Hot pursuit: Facts immediately following a crime provide probable cause.
– Escapees: Immediate capture.
#### Historical Background:
– The decision provided a clearer scope of lawful entrapments—vital for anti-narcotics operations where civilian informants and buy-busts are common.
– The ruling safeguards constitutional protections on searches and seizures, balancing law enforcement needs and individual rights.
– The verdict illustrates judicial restraint against potential abuses of power within entrapment and search processes.
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