Tuesday, June 20, 2017

Case Digest: People vs. Sembrano

G.R. No. 185848
People Vs. Michael Castro Sembrano
August 16, 2010

Facts:
In a buy-bust operation and after a follow up search, Accused Appellant was arrested and charged with the violation of Section 5 (illegal sale) and Section 11, Article II (illegal possession) of R.A. 9165. He was then found guilty by the lower courts.

Accused-appellant appealed the lower court’s ruling, contending that the arrest made on him was illegal and thus the alleged evidence seized during such warrantless arrest shouldn’t have been admitted (‘fruit of the poisonous tree doctrine”). He further averred that he had been framed by the police officers.

Ruling:
The court held that the arrest made was legal. Appellant was arrested during an entrapment operation where he was caught in flagrante delicto selling shabu. When an arrest is made during an entrapment operation, it is not required that a warrant be secured in line with the provisions of Rule 113, Section 5(a) of the Revised Rules of Court allowing warrantless arrests.

The contention of frame-up in the case at bar could not be looked upon by the Court with favor in light of straightforward and positive testimony of poseur-buyer identifying him as the seller of shabu. Moreover, the accused-appellant failed to prove that there had been ill-motive on the part of the officers to impute such crimes. Police officers are presumed to have performed their duties in a regular manner, unless there is evidence to the contrary.


Court found the accused-appellant guilty beyond reasonable doubt and was sentenced to an indeterminate penalty of imprisonment ranging from twelve (12) years and one (1) day, as minimum, to fourteen (14) years, as maximum, and to pay a fine of Three Hundred Thousand Pesos (P300,000.00) for illegal possession of 0.27 grams of shabu.  For illegal sale of drugs, regardless of quantity, he was sentenced to suffer the penalty of LIFE IMPRISONMENT and to pay a fine in the amount of FIVE HUNDRED THOUSAND PESOS (P500,000.00) PESOS; 

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