- Petitioner
- People
- Respondent
- Florencio Doria
- Citation
- G.R. No. 125299
- Court
- Supreme Court
- Division
- En Banc
- Ponente
- Puno, J.
- Decided
- January 22, 1999
Summary
The Supreme Court modified a Regional Trial Court conviction in a drug trafficking case involving a buy-bust operation. While upholding Florencio Doria's conviction for selling 970 grams of marijuana but reducing his sentence from death to reclusion perpetua, the Court acquitted Violeta Gaddao due to illegal warrantless arrest and unconstitutional search of her residence. The decision significantly clarified Philippine jurisprudence on entrapment versus instigation, emphasizing that entrapment by law enforcement is permissible while instigation is prohibited. The Court applied strict scrutiny to buy-bust operations, requiring clear proof of all transaction details, and reinforced constitutional protections against unreasonable searches and seizures. The ruling established important precedents for evaluating the validity of warrantless arrests and the plain view doctrine in drug cases, balancing law enforcement needs with individual constitutional rights.