Facts:

The case involves Ignacio Balicanta III y Cuarto (petitioner) against the People of the Philippines (respondent), with the decision rendered by the Supreme Court on June 26, 2023. The events leading to the case unfolded on November 16, 2013, in Quezon City, Philippines. On that day, at approximately 10:00 a.m., Balicanta was driving a motorcycle without a helmet when he was flagged down by police officers from the Quezon City Police District, including Police Officer III Romualdo Dimla and Police Officer III Danilo Zapatero. Upon being asked for his driver's license, Balicanta presented an expired one and claimed to be a police intelligence operative, showing an identification card purportedly signed by Superintendent Bernabe Mendoza. The officers, suspecting the authenticity of his claim, requested him to open his belt bag, which led to the discovery of a Firestorm .45 caliber pistol, a magazine, eight live rounds of ammunition, and a fan knife. Balicanta was arrested af...

Facts:

Incident and Arrest

On November 16, 2013, at around 10:00 a.m., Police Officers Romualdo Dimla, Danilo Zapatero, Leonard Valiente, and George De Leon of the Quezon City Police District were patrolling along Mapagbigay Street corner Matapang Street, Barangay Pinyahan, Quezon City. They flagged down Ignacio Balicanta III, who was driving a motorcycle without a helmet. When asked to produce his driver’s license, Balicanta presented an expired one. He then introduced himself as a police intelligence operative, presenting an identification card signed by a certain Superintendent Bernabe Mendoza. The officers, knowing that Superintendent Bauto was the incumbent district intelligence division chief, became suspicious and asked Balicanta to open his belt bag. Inside, they found a Firestorm .45 caliber pistol, a magazine loaded with eight live ammunition, and a fan knife.

Investigation and Charges

Balicanta was asked to produce the necessary documents for the firearm. He presented a firearm license belonging to Mardito Baesa Garcia, but the serial number on the license did not match the firearm. Balicanta was arrested and brought to the police station. The confiscated items were photographed and marked in his presence. A Joint Affidavit of Arrest was executed, and a referral to the inquest prosecutor was prepared for charges of driving without a helmet, driving with an expired license, usurpation of authority, and illegal possession of firearms.

Trial and Conviction

During the trial, Balicanta denied the charges, claiming he was drinking soft drinks when he was arrested and that the police demanded PHP 80,000.00 from him to drop the case. The Regional Trial Court convicted Balicanta of illegal possession of firearms under Section 28(a) of Republic Act No. 10591, sentencing him to an indeterminate penalty of three years of prision correccional as minimum to eight years and one day of prision mayor as maximum. The Court of Appeals affirmed the conviction but modified the penalty to eight years of prision mayor as minimum to nine years and four months of prision mayor as maximum.

Issue:

1. Whether Balicanta’s arrest was valid.
2. Whether the Court of Appeals correctly upheld Balicanta’s conviction for illegal possession of firearms.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Conclusion:

The Supreme Court acquitted Balicanta due to the invalidity of his arrest, the inadmissibility of the evidence obtained from an invalid search, and the failure of the prosecution to preserve the integrity of the confiscated items. The confiscated firearm and ammunition were ordered to be turned over to the Philippine National Police-Firearms and Explosives Office for proper disposal.