Title
People vs. Lacson y Marquesses
Case
G.R. No. 248529
Decision Date
Apr 19, 2023
Police arrested three men during a patrol, finding weapons without permits. The Supreme Court acquitted them, ruling the warrantless arrest and search unlawful, rendering evidence inadmissible.

Case Digest (G.R. No. 248529)
Expanded Legal Reasoning Model

Facts:

  • Parties and Procedural History
    • Plaintiff-Appellee: People of the Philippines; Accused-Appellants: Mark Alvin Lacson y Marquesses and Noel Agpalo y Sacay; Co-accused: Moises Dagdag y Corpuz.
    • Five separate Informations (Crim. Case Nos. 152327–152331-TG) charged them with:
      • Illegal possession of a hand grenade (P.D. No. 1866 as amended).
      • Illegal possession of a hand grenade during the election period (Comelec Resolution No. 9735).
      • Illegal possession of a “paltik” revolver and live ammunition (RA 10591).
      • Possession of the same firearms/ammunition during the election period (Comelec Resolution No. 9735).
      • Illegal carrying of a bladed weapon during the election period (Comelec Resolution No. 9735).
  • Arrest, Evidence and Trial
    • On October 7, 2013, members of the Taguig Police’s Tactical Motorcycle Riders Unit, under “Oplan Sita,” received a report on a snatching along C-5 Road, saw Lacson, Agpalo, and Dagdag loitering, and approached them. The three fled but were intercepted.
    • Frisking recovered from Agpalo a loaded “paltik” revolver with four live rounds; from Lacson a hand grenade. Dagdag was separately apprehended; a bladed weapon was allegedly seized from him.
    • Defendants denied ownership, claimed frame-up and brutality. At the precinct, police allegedly used Agpalo’s phone to lure him in and then arrested him.
    • RTC (Sept. 5, 2017) convicted Lacson and Agpalo of the charged offenses, acquitted Dagdag for lack of proof, and ordered forfeiture of seized items.
    • CA (Jan. 17, 2019) affirmed RTC, ruling appellants had waived any arrest/search irregularity by not quashing the Informations before arraignment.

Issues:

  • Whether the warrantless arrests of Lacson and Agpalo were valid.
  • Whether the warrantless searches (stop-and-frisk) yielding the grenade, firearm, and ammunition were valid.
  • Whether the guilt of Lacson and Agpalo was proven beyond reasonable doubt.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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