G.R. No. 110613 - People vs. Villanueva

On July 14, 2012, in Bacolod City, Ian Agravante y De Oca was charged under PD No. 1866, as amended by RA No. 8294, with illegal possession of one improvised homemade firearm, one .12‐gauge live ammunition, two .357 live ammunitions, and one .357 live ammunition in its barrel, all without a permit.
The Information alleged that these items matched those reported stolen from Engineer Vicente Genova’s vehicle.

At 3:10 a.m., PNP-MPG recorded Genova’s report of stolen items, including a Walther P99 pistol, magazines with live ammunition, and bags.
Police interviewed Romeo Tabigne, who identified petitioner and two companions as perpetrators and located them at a house in Purok Kagaykay, Barangay 2.
Around 2:00 p.m. (over 11 hours later), PO1 Teodorico peered through bamboo slats, spotted petitioner sleeping beside two bags, entered the house, and opened the bags.
They found in one bag a Walther P99 magazine and 27 rounds of .40 caliber ammunition; in another, an improvised firearm with a chambered .357 round and two .357 rounds; upon frisking, a shotgun round was recovered from petitioner’s pocket.
PO1 Teodorico marked the improvised gun and cartridges; other recovered items were returned to Genova; petitioner was arrested for lacking a permit.

Petitioner asserted he was merely exploring Bacolod City, met Tabigne, and was left alone in a house where he fell asleep; he denied any knowledge of the stolen items or firearms.
He alleged he was beaten by police upon waking and again at the station, but presented no medical records or complaints.

On September 28, 2017, RTC Branch 44, Bacolod City, convicted petitioner of illegal possession of firearm and ammunition, sentenced him to an indeterminate penalty of 4 years, 2 months, 1 day to 6 years, 8 months, 1 day, and imposed a ₱30,000 fine.
On September 8, 2020, the CA in CA-G.R. CEB-CR 03144 affirmed the RTC Decision; on May 27, 2021, it denied the Motion for Reconsideration.

Petitioner elevated the case to the Supreme Court, assigning errors: (a) illegality of his warrantless arrest and inadmissibility of seized evidence; and (b) insufficiency of evidence to prove guilt beyond reasonable doubt.
The Supreme Court granted the petition, reviewed the entire case, and focused on the legality of the arrest and search.

Whether petitioner’s warrantless arrest and the ensuing search were valid, or whether they rendered the seized firearm and ammunition inadmissible.
Whether the prosecution’s evidence sufficiently proved petitioner’s guilt beyond reasonable doubt for illegal possession of firearm and ammunition.