Yuhanon v. People

Summary

Randy Yuhanon was convicted by lower courts for illegal possession of 0.118 grams of methamphetamine hydrochloride (shabu) under RA 9165 after police seized four plastic sachets during a warrantless arrest in Tondo, Manila on December 21, 2011. The Supreme Court reversed his conviction, ruling that the warrantless arrest was unlawful because Yuhanon's act of examining a plastic sachet while walking did not constitute an overt criminal act justifying arrest under the in flagrante delicto exception. The Court found the subsequent search invalid and the seized drugs inadmissible as fruit of the poisonous tree, emphasizing that mere suspicious behavior without clear criminal activity cannot justify warrantless arrest. This case reinforces constitutional protections against unreasonable searches and seizures and establishes strict standards for warrantless arrests in drug cases.