Facts:

• The case involves Rolito Go y Tambunting (petitioner) against the People of the Philippines, the Court of Appeals, and Hon. Benjamin V. Pelayo, Presiding Judge of Branch 168, Regional Trial Court, NCJR Pasig, M.M.
• On July 2, 1991, Eldon Maguan was driving on Wilson Street, San Juan, Metro Manila, when Go entered the one-way street in the opposite direction, nearly colliding with Maguan's vehicle.
• Go exited his car and shot Maguan inside his vehicle before fleeing the scene.
• A security guard noted Go's car plate number, traced to his wife, Elsa Ang Go.
• Police collected an empty shell and a live round from the scene shortly after the incident.
• Investigations revealed Go had dined nearby before the shooting.
• On July 8, 1991, Go voluntarily presented himself at the San Juan Police Station with two lawyers, following reports of a manhunt.
• An eyewitness identified Go as the shooter, leading to a complaint for frustrated homicide filed against him.
• Prosecutor Dennis Villa Ignacio informed Go, in the presence of his lawyers, about the option for a preliminary investigation, which Go refused to waive.
• Maguan died from his injuries on July 9, 1991, prompting the prosecutor to file murder charges on July 11, 1991, without bail recommendation.
• Go's counsel filed a motion for immediate release and a proper preliminary investigation, claiming the warrantless arrest was unlawful.
• The trial court granted a cash bond of P100,000.00 for Go's release on July 12, 1991.
• On July 17, 1991, the trial judge recalled the bail and set a hearing for July 23, 1991.
• Go filed a petition for certiorari, prohibition, and mandamus with the Supreme Court, challenging the trial court's order.
• The Court of Appeals consolidated and dismissed the petitions on September 23, 1991, leading to the current petition for review on certiorari.

Issue:

• (Unlock)

Ruling:

• The Supreme Court ruled that the warrantless arrest of Rolito Go was not valid.
• The Court held that Rolito Go did not ...(Unlock)

Ratio:

• The Supreme Court determined that the warrantless arrest was invalid as it occurred six days after the alleged crime, and the arresting officers lacked personal knowledge of the crime at the time of arrest.
• The Court emphasized that an arrest must occur immediately after the offense, which was not the case here.
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