A valid warrantless arrest can be conducted when a peace officer has

personal knowledge of facts indicating the commission of a crime.

Furthermore, for a waiver of rights to be valid, it must be voluntary,
knowing, and intelligent, and the waiver should be in writing and in the
presence of the accused's counsel to ensure its validity.

People of the Philippines vs. Rosalinda D. Ramos

G.R. Nos. 85401-02, GUTIERREZ, JR., June 04, 1990

Facts:
The defendant, Rosalinda Ramos y David, was accused of selling
marijuana cigarettes. However, the prosecution failed to present the
alleged poseur-buyer during the trial. The police officers who effected
the arrest were situated three blocks away from where the supposed
sale took place and did not witness the sale themselves. The defense
claimed that the marked money found in the defendant's possession
could have been received through legitimate transactions as she was a
cigarette vendor.

Issue/s:
The investigation procedures were questioned for not adequately
informing the accused of her rights in terms she could understand.

The waiver of right to counsel by the accused was not properly executed
as required by the constitution since it was neither in writing nor in the
presence of counsel.

The presence and identity of the poseur-buyer were crucial to the case, as
their absence left no convincing evidence of the defendant selling
marijuana.
Consequent to the arrest without a warrant was deemed valid based on
information from an informant, despite the failure to establish the sale
of marijuana beyond reasonable doubt.

Held:
The Court emphasized the necessity of effectively communicating the
rights of an individual under interrogation in terms understandable to
them, ensuring comprehension is achieved. The lack of a proper waiver
of the right to counsel and the failure to present critical testimony from
the poseur-buyer resulted in insufficient evidence to unequivocally
establish the sale of marijuana by the accused. Reiterates the
importance of direct and positive evidence in drug-related cases,
especially when severe penalties like reclusion perpetua are involved.
The legality of the arrest without a warrant was maintained,
considering the officers had reasonable grounds based on informant's
information, regardless of the prosecution's failure to prove the sale
beyond reasonable doubt.

Regarding possession of prohibited drugs, the Court found the evidence

against the defendant to satisfy the requisites for conviction based on
her control and access to the contraband's location.

WHEREFORE, the appealed decision in Criminal Case No. 5990 is

AFFIRMED but MODIFIED. The appellant is sentenced to suffer the
penalty of imprisonment ranging from six (6) years and one (1) day to
nine (9) years and to pay a fine of six thousand (P6,000) pesos. The
appealed decision in Criminal Case No. 5991 is REVERSED and SET
ASIDE and the appellant is acquitted on grounds of reasonable doubt.