- Petitioner
- People
- Respondent
- Guzman
- Citation
- G.R. No. 117952-53
- Court
- Supreme Court
- Division
- First Division
- Ponente
- YNARES-SANTIAGO
- Decided
- February 14, 2001
Summary
The Supreme Court affirmed the conviction of Danilo de Guzman for illegal possession of 299.5 grams of shabu and an unlicensed firearm following a police surveillance operation at a Cavite beach resort. The Court upheld the validity of the warrantless arrest, ruling that De Guzman was caught in flagrante delicto when police observed him carrying a visible firearm without proper license, immediately constituting a crime under PD 1866. The subsequent search incident to arrest and seizure of drugs under the plain view doctrine were deemed constitutional. However, the Court modified the drug possession penalty from life imprisonment to an indeterminate sentence of 6 years and 1 day to 12 years with P12,000 fine, properly applying RA 6425 and the Indeterminate Sentence Law. The case establishes important precedent on the scope of warrantless arrests for firearm violations and the application of search incident to arrest doctrine in drug cases.