"... there must first be a lawful arrest before a search is made.:"

A search incidental to a lawful arrest requires that there must first be a lawful arrest before a search is made. Otherwise stated, a lawful arrest must precede the search; "the process cannot be reversed."[78] For there to be a lawful arrest, law enforcers must be armed with a valid warrant. Nevertheless, an arrest may also be effected without a warrant.

Precedents/Link/Source: 
[78] People v. Racho, 640 Phil. 669, 676 (2010) [Per J. Nachura, Second Division].

2017 Latest Application. READ Full Text.
[2017V331] Veridiano vs PP