G.R. No. 145363 - Gonzales vs. Rosas

Accused-appellants: Leng Haiyun, Dang Huiyin, Liu Wen Xion a.k.a. “Lui Xin,” and Lei Guang Feng, Chinese nationals.
Charged in three Informations dated May 28, 2013 in Pasuquin, Ilocos Norte:

Criminal Case No. 2131-19 – Illegal possession of explosives (8 live hand grenades, main charges, alleged explosives) under Section 3, P.D. No. 1866 as amended.
Criminal Case No. 2132-19 – Illegal possession of firearms and ammunition (various submachine guns, pistols, magazines, ammunitions, silencers) without license.
Criminal Case No. 2133-19 – Violation of election gun ban, carrying the same firearms and explosives during election period, without COMELEC permit.

May 28, 2013, around 6:30 PM – Gasoline station attendant Michael Claveria observed a silver-gray Toyota Previa break two bottles near the pumps and reported it to police.
Patrol team led by Police Inspector (PI) Joseph Tayaban responded, spotted the Previa; accused-appellants fled north.
Police chased and requested COMELEC checkpoint personnel in Barangay Davila to intercept the vehicle.
Upon stopping at checkpoint, PI Tayaban signaled for the tinted window to be lowered, saw four foreigners and multiple plate number plates on the floor, and asked for passports—none were shown.
Driver handed officer a phone call from “Candy” requesting their release; Tayaban insisted they accompany police to station.

En route, PI Tayaban boarded the Previa to prevent escape; upon arrival at station, instructed accused-appellants to alight.
In plain view under the second-row seat, officers saw firearm butts and barrels. Area was cordoned and accused-appellants handcuffed.
Additional PPO personnel (PS Baldeo, PCI De Guzman) and media were present; PCI De Guzman opened sliding door, discovering an MP5 submachine gun, other firearms, eight hand grenades, explosive charges, and plate numbers.
Officer 2 Llamelo inventoried and Officer 3 Bulosan marked each seized item.

Convicted in Crim. Case No. 2131-19 – Illegal possession of explosives; sentenced to reclusion perpetua.
Convicted in Crim. Case No. 2133-19 – Election gun ban violation; indeterminate sentence of 2–5 years.
Dismissed Crim. Case No. 2132-19 – Illegal possession of firearms (per Agote v. Lorenzo, double jeopardy considerations).
Ordered forfeiture and confiscation of contraband.

Whether the warrantless arrest of accused-appellants and subsequent warrantless search and seizure of the Previa were valid under Rule 113, Section 5 of the Rules of Court.
Whether convicting accused-appellants of both illegal possession of explosives and election gun ban violation violates double jeopardy or lacks proof of animus possidendi.