Facts:

This case involves Junel Alaska as the petitioner and SP02 Gil M. Garcia, PO3 Romy P. Galicia, and PO2 Ruzel S. Briones as respondents. The dispute originated from an incident on September 24, 2010, when a robbery with homicide transpired at the Petron Gasoline Station owned by Leoncio and Josefina Docena in Poblacion District II, Brooke’s Point, Palawan. During the robbery, four armed men stole P70,000 from the station's income and shot an employee, Romeo Tamaro. Although police officers responded quickly, they were unable to apprehend the assailants initially. In the following days, an investigation was conducted which included interviewing witnesses. A key breakthrough came when Lilia Agda, an employee, mistakenly sent a message to a cellphone that had been stolen during the robbery. Through a series of text exchanges with the alleged culprits, police identified Alaska and another individual, Adolfo Montesa, as suspects. They were arrested on September 29, 2010, while in

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Facts:

Incident and Initial Criminal Activity

• On September 24, 2010, a robbery with homicide occurred at the Petron Gasoline Station in Poblacion District II, Brooke’s Point, Palawan.
• Four armed men robbed the station of ₱70,000.00 and fatally shot Romeo Tamaro, an employee of the station.
• The robbery took place at a gasoline station owned by Leoncio and Josefina Docena.

Investigation and Identification of Suspects

• Police officers promptly responded to the incident but were unable to immediately apprehend the culprits.
• In the following days, through interviews and investigation, the police gathered evidence linking suspects to a cellphone used during the robbery.
• A cook at the station, Lilia Agda, mistakenly sent a message to a cellphone purportedly belonging to one of the robbers, which inadvertently aided the investigation.
• Jovy Abastillas, an employee, interacted via text messages with the cellphone number, further assisting the police in tracking the suspects.
• The investigation resulted in the identification of Junel Alaska and Adolfo Montesa as suspects when they were located in Barangay Ocayan, Bataraza, Palawan, on September 29, 2010.

Arrest, Criminal Charges, and Preliminary Proceedings

• Alaska and Montesa were apprehended when Alaska was overheard conversing on the cellphone with Jovy; the call register from the seized cellphone substantiated this evidence.
• Both suspects were brought to the Rio Tuba Police Station and were identified by witnesses as participants in the robbery.
• They were subsequently charged with Robbery with Homicide before the Regional Trial Court (RTC) of Puerto Princesa City.
• Prior to arraignment, the suspects filed an Omnibus Motion to Judicially Determine Probable Cause and to quash both the information and the arrest warrant, arguing their warrantless arrests were unlawful.

Filing of Complaints Against Arresting Officers and the Ombudsman’s Action

• On August 23, 2011, Alaska and Montesa filed a Complaint-Affidavit for Misconduct against SPO2 Gil M. Garcia, PO3 Romy P. Galicia, and PO2 Ruzel S. Briones.
• They also filed a Joint Complaint Affidavit for Arbitrary Detention on October 11, 2011, before the Office of the Ombudsman.
• On April 24, 2012, the Ombudsman issued a Joint Resolution dismissing both the administrative and criminal complaints on the grounds that issues regarding the legality of the arrest should have been raised before the RTC at arraignment.
• Alaska and Montesa subsequently sought reconsideration of the Ombudsman’s Joint Resolution, which was denied in a Joint Order on November 23, 2012.

Procedural History Leading to the Petition for Review

• The RTC, in a Resolution dated May 21, 2014, ruled in favor of Alaska and Montesa by dismissing the charges, citing insufficient evidence and a contrived basis for the arrest and subsequent indictment.
• Despite the RTC’s findings, the Court of Appeals (CA) in its Decision dated June 29, 2016, dismissed the petition filed under Rule 43, holding that because no objection to the arrest was raised at arraignment, any irregularity was waived.
• The CA’s dismissal was later reaffirmed in a Resolution issued on November 10, 2016, prompting Alaska to file the present Petition for Review on Certiorari.

Issue:

• Whether the CA validly dismissed Alaska’s petition on the basis that he raised no objection regarding the irregularity of his arrest before arraignment, thereby submitting to the jurisdiction of the trial court.
• Whether the Ombudsman erred in holding that the accused’s prior objection—or failure to object—to the legitimacy of the arrest before the RTC precluded the filing of administrative and criminal cases (for Misconduct and Arbitrary Detention) against the arresting officers.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)