Case Digest (G.R. No. 233777)
Facts:
In Marvin Porteria y Manebali v. People of the Philippines (G.R. No. 233777, March 20, 2019), the petitioner Marvin was accused of carnapping a blue 2004 Honda motorcycle belonging to Wilfredo Christian P. Mien, which Christian had parked in front of St. John Hospital, Naga City, on December 10, 2010. After discovering his motorcycle missing, Christian filed a theft report with the Naga City Police. On February 1, 2011, police officers in Ocampo, Camarines Sur, acting on an anonymous tip about a suspicious person with something “tucked in his waist,” arrested Marvin for illegal possession of a firearm and conducted a warrantless search of his person and bag. They allegedly found photocopies of the motorcycle’s Official Receipt (OR) and Certificate of Registration (CR). At the police station, Marvin allegedly told Police Inspector Villamer that the motorcycle was with one Felix in Sta. Rosa, Laguna. Christian’s mother, Virgie, later visited Marvin in custody and testified that hCase 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)