COORDINATION WITH THE PDEA IS NOT AN INDISPENSABLE REQUIREMENT BEFORE POLICE AUTHORITIES MAY CARRY OUT A BUY-BUST OPERATION

While it is true that Section 86 of Republic Act No. 9165 requires the National Bureau of Investigation, PNP and the Bureau of Customs to maintain "close coordination with the PDEA on all drug-related matters," the provision does not, by so saying, make PDEA's participation a condition sine qua non for every buy-bust operation. After all, a buy-bust is just a form of an in flagrante arrest sanctioned by Section 5, Rule 113 of the Rules of the Court, which police authorities may rightfully resort to in apprehending violators of Republic Act No. 9165 in support of the PDEA. A buy-bust operation is not invalidated by mere non-coordination with the PDEA. (PEOPLE OF THE PHILS. VS. ALLEN UDTOJAN MANTALABA, G.R. NO. 186227, JULY 20, 2011, PERALTA, J.).