Asto. Adm. No. 743 - Aguirre vs. Ramos

Eduardo Celedonio (petitioner) was charged with Robbery with Force Upon Things under Article 299(a) of the Revised Penal Code.
The charge stemmed from an incident on April 22, 2007, in Navotas, Metro Manila, where Celedonio was accused of unlawfully entering the house of Carmencita De Guzman by destroying the backdoor and stealing numerous valuable items worth Php223,000.00.

Adriano Marquez, a neighbor, witnessed the robbery on the evening of April 21, 2007, while De Guzman was at a wake.
Marquez identified Celedonio as the culprit entering and ransacking De Guzman’s house.
Marquez reported the incident, and the police, assisted by Marquez, conducted a follow-up operation.
During said operation, Marquez pointed to Celedonio on a motorcycle; upon police inquiry, Celedonio opened his motorcycle compartment revealing stolen items.
Celedonio admitted those items were the stolen ones when asked.
Celedonio was arrested and informed of his constitutional rights; more stolen items were seized at the police station.

Celedonio filed a Demurrer to Evidence citing illegal arrest and illegal search. The RTC denied this motion.
Celedonio claimed an alibi, stating he was home asleep with his wife who corroborated his claim at the time of the incident.
He denied possession of stolen items, alleging they were planted by police to frame him.

The RTC found Celedonio guilty beyond reasonable doubt and sentenced him to an indeterminate penalty of 4 years and 2 months to 8 years and 1 day imprisonment.
He was ordered to pay Php108,000.00 as damages for unrecovered items.
The RTC concluded that robbery occurred recently, stolen items were found in Celedonio’s possession, and Celedonio had no valid explanation for such possession.

Celedonio appealed the conviction citing: insufficiency of circumstantial evidence; alleged illegal search and seizure; and alleged ill-motivation of witness Adriano Marquez.
The CA affirmed the RTC decision, holding that the circumstantial evidence established guilt beyond reasonable doubt.
The CA ruled the search was not illegal as Celedonio voluntarily opened his motorcycle compartment before any arrest or search.
The CA found that Celedonio waived the right to question the arrest since he did not raise the issue before arraignment.
Marquez’s credibility was upheld as there was no evidence of ill-motivation or bad character sufficient to impeach him.
Celedonio’s motion for reconsideration was denied, leading to the present petition for review to the Supreme Court.

Whether the Court of Appeals erred in affirming the conviction based on circumstantial evidence.
Whether the Court of Appeals erred in not finding the search and seizure conducted on the petitioner illegal, thereby rendering the recovered items inadmissible.
Whether the Court of Appeals erred in not recognizing the alleged ill-motivation of the prosecution witness Adriano Marquez in testifying against the petitioner.