Case Digest (G.R. No. 257450)
Facts:
The case involves Ian Agravante y De Oca (petitioner) against the People of the Philippines (respondent). The events leading to the case unfolded on July 14, 2012, in Bacolod City, Negros Occidental. The petitioner was charged with illegal possession of a firearm and ammunition under Presidential Decree No. 1866, as amended. The Information alleged that on the aforementioned date, Agravante unlawfully possessed an improvised homemade firearm and several live ammunition without the necessary permits.
The incident began when the Philippine National Police Mobile Patrol Group (PNP-MPG) received a report from Engineer Vicente Genova about items stolen from his vehicle. The stolen items included a black firearm case containing a .40 caliber P99 Walther pistol, magazines, and various live ammunition. Following the report, police officers, including PO1 Edward M. Teodorico, conducted an investigation and interviewed witnesses, including one Romeo Tabigne, who implicated Agravante...
Case Digest (G.R. No. 257450)
Facts:
Incident and Initial Report
- On July 14, 2012, at around 3:10 a.m., the Philippine National Police Mobile Patrol Group (PNP-MPG) received a report from Engineer Vicente Genova that several items, including a firearm, ammunition, and bags, were stolen from his vehicle parked in Bacolod City.
Investigation and Tip
- PO1 Edward M. Teodorico and his team investigated the scene and interviewed Romeo Tabigne, who claimed to have witnessed the theft. Tabigne identified Rainhart Colangco, a certain Balweg, and petitioner Ian Agravante y De Oca as the perpetrators.
Arrest and Search
- At around 2:00 p.m. on the same day, Tabigne led the police to a house in Bacolod City where petitioner was allegedly staying. The police peered through the window and saw petitioner sleeping inside. They entered the house, found two bags beside him, and discovered an improvised firearm, live ammunition, and other items matching the description of the stolen goods. Petitioner was arrested when he failed to present a license or authority to possess the firearms and ammunition.
Petitioner’s Defense
- Petitioner denied the charges, claiming he was merely visiting Bacolod City and was asleep in a friend’s house when the police entered and arrested him. He alleged that he was mauled by the police and denied any knowledge of the stolen items. However, he did not file any formal complaint against the officers.
Trial Court Decision
- On September 28, 2017, the Regional Trial Court (RTC) found petitioner guilty of illegal possession of firearm and ammunition under Presidential Decree No. 1866, as amended, and sentenced him to imprisonment and a fine.
Court of Appeals Decision
- The Court of Appeals (CA) affirmed the RTC’s decision, ruling that petitioner’s warrantless arrest and the subsequent search were valid under Section 5(b) of Rule 113 of the Revised Rules on Criminal Procedure. The CA also held that petitioner waived his right to question the legality of his arrest by failing to raise it before his arraignment.
Issue:
- Whether petitioner’s warrantless arrest and the search conducted were lawful.
- Whether the evidence obtained from the search is admissible.
- Whether the prosecution proved petitioner’s guilt beyond reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court granted the petition, reversed the CA’s decision, and acquitted petitioner Ian Agravante y De Oca due to the illegality of his arrest and the inadmissibility of the evidence obtained from the unreasonable search.