Case Digest (G.R. No. 173861)
Facts:
Jay Candelaria and Eric Basit v. Regional Trial Court, Branch 42, City of San Fernando (Pampanga), G.R. No. 173861, July 14, 2014, the Supreme Court Second Division, Del Castillo, J., writing for the Court.Petitioners Jay Candelaria and Eric Basit were arrested during an alleged buy-bust operation on the evening of June 22, 2001, at the corner of Gueco Street and MacArthur Highway, Balibago, Angeles City, for delivering with intent to sell five cases of purportedly counterfeit Fundador brandy. A Joint Affidavit of the arresting officers supported the arrest, and an Information dated July 6, 2004 charged petitioners with violation of Section 155 in relation to Section 170 of Republic Act No. 8293 (Intellectual Property Code). Petitioners were arraigned and pleaded not guilty on May 31, 2005.
On June 17, 2005 petitioners filed a Motion to Suppress/Exclude Evidence, asserting that the evidence to be used against them was obtained in violation of their constitutional right against unreasonable searches and seizures because they were not caught committing a crime in the presence of the arresting officers. The Regional Trial Court (RTC), Branch 42, denied that motion in an Order dated October 12, 2005. The RTC observed that objections to arrests must be raised before plea on arraignment and, having not moved to quash before arraignment, petitioners were estopped; alternatively, the RTC found from the Joint Affidavit that the seizure was incidental to a valid warrantless arrest in flagrante delicto, rendering the evidence admissible. Petitioners' Motion for Reconsideration was denied by the RTC in an Order dated July 14, 2006.
Dissatisfied, petitioners filed a Petition for Certiorari under Rule 65 of the Rules of Court (with application for preliminary injunction) in the Supreme Court seeking to annul the RTC’s Orders denying their Motion to Suppress and its denial of re...(Pro-only)
Issues:
- Did the Regional Trial Court commit grave abuse of discretion amounting to lack or excess of jurisdiction in denying petitioners’ Motion to Suppress/Exclude Evidence and in denying their Motion for Recon...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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