Title
Porteria y Manebali vs. People
Case
G.R. No. 233777
Decision Date
Mar 20, 2019
Motorcycle theft case: Marvin acquitted due to illegal search, inadmissible confession, and insufficient evidence linking him to the crime.

Case Digest (G.R. No. 233777)

Facts:

  • Background and Complaint
    • On December 10, 2010, Wilfredo Christian P. Mien parked his Honda motorcycle (2004 model, Plate No. EL5401) at St. John Hospital, Naga City, and later found it missing.
    • Christian reported the theft to the PNP Naga City Police Precinct 2 and to the PNP Provincial Highway Patrol Group, filing an Alarm Sheet, Complaint Sheet, and submitting registration documents.
  • Arrest and Alleged Confessions
    • On February 1, 2011, an anonymous tip of a “suspicious person” led Ocampo, Camarines Sur police (SPO4 Pequiras and P/Insp. Villamer) to arrest Marvin Porteria y Manebali for illegal possession of a firearm; a search of his bag allegedly uncovered photocopies of the stolen motorcycle’s OR and CR.
    • Marvin was brought to the police station and questioned without being informed of his rights; he allegedly told P/Insp. Villamer that the motorcycle was with a certain Felix in Sta. Rosa, Laguna.
    • On February 5, 2011, Christian’s mother, Virgie P. Mien, visited Marvin at Naga City District Jail; she testified that Marvin orally admitted stealing the motorcycle and leaving it with “Insan Joy” in Sta. Rosa.
  • Recovery of Motorcycle and Trial Proceedings
    • On March 11, 2011, a checkpoint in Barangay Kaingin, Sta. Rosa, Laguna, led to the apprehension of Albert Orino driving the stolen motorcycle; Albert denied ownership and was charged for driving without a license.
    • On October 27, 2011, the RTC of Naga City indicted Marvin, Albert, and Felix for carnapping; Marvin pleaded not guilty, was tried by circumstantial evidence, and on December 5, 2014, was convicted and sentenced to 14 years, 8 months, and 1 day to 15 years’ imprisonment.
    • The CA, in a May 12, 2017 Decision (affirmed August 16, 2017 on reconsideration), upheld the conviction; Marvin filed a Rule 45 petition with the SC.

Issues:

  • Whether the warrantless search and seizure of Marvin’s person and belongings was valid.
  • Whether Marvin’s alleged admissions to P/Insp. Villamer and to Virgie P. Mien were admissible.
  • Whether the remaining circumstantial evidence sufficed to establish guilt beyond reasonable doubt.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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