Case Digest (G.R. No. 254800)
Facts:
Bryan Ta-Ala y Constantino v. People of the Philippines, G.R. No. 254800, June 20, 2022, Supreme Court Second Division, Lazaro-Javier, J., writing for the Court. Petitioner Bryan Ta-Ala y Constantino (petitioner) sought review of the Court of Appeals' Decision dated May 9, 2019 and Resolution dated January 30, 2020 in CA-G.R. SP No. 10697 and CA-G.R. SP No. 10873 which had affirmed the denial of his motions to quash informations and to suppress evidence in several criminal cases charging violations of R.A. No. 10591 (Comprehensive Firearms and Ammunition Regulation Act) and provisions of the Tariff and Customs Code.On August 6, 2016, SPO4 Liberato S. Yorpo and SPO1 Jerome G. Jambaro of the CIDG, Negros Occidental effected a warrantless arrest of petitioner and Wilford Palma y Zarceno (alias Michael Diamante). The arresting officers executed an Affidavit of Arrest on August 8, 2016 before Assistant State Prosecutor Michael A. Vito Cruz, narrating that they saw a Glock 26 pistol tucked in petitioner’s waist and also that the same or identical firearm and numerous firearm parts were found inside a box delivered by Atlas Shippers which Palma allegedly claimed. The Affidavit and an accompanying Letter-Complaint by CIDG Chief Intel P/SSupt. Randy Glenn G. Silvio became exhibits in the DOJ inquest docketed NPS Docket No. XVI-INQ-16H-00110.
Assistant State Prosecutor Vito Cruz issued a Resolution dated August 22, 2016 finding probable cause to file two informations under Section 28 of R.A. No. 10591 (illegal possession of firearm and illegal possession of firearm accessories) against petitioner; a later Resolution dated September 13, 2016 found probable cause for violation of Section 33 of R.A. No. 10591 (arms smuggling) and for offenses under Sections 101(a) and 3601 of the Tariff and Customs Code. The DOJ filed multiple informations before various RTC branches in Bacolod City (docketed Criminal Case Nos. 16-43163; 16-43164; 16-43487; 16-43488). Petitioner posted bail in some cases but was not released, and he filed motions to quash and to suppress evidence in the trial courts alleging illegal warrantless arrest, defective inquest/preliminary investigation, and other procedural defects.
RTC-Branch 46 denied the motion to quash in Criminal Case No. 16-43163 and admitted an amended information; RTC-Branch 54 denied the omnibus motion in Criminal Case No. 16-43487 and admitted an amended information for illegal importation of firearm accessories, further denying bail. Petitioner filed two petitions for certiorari in the Court of Appeals (CA-G.R. SP Nos. 10697 and 10873) challenging those RTC dispositions; the CA consolidated and dismissed them for lack of merit, holding the warrantless arrest valid and the motions moot after arraignment. Petitioner filed this Petition for Review on Certiorari under Rule 45 to the Court, asserting that the arrest was illegal (pointing to irrec...(Pro-only)
Issues:
- Is the Petition academic or moot in light of petitioner’s arraignment and subsequent proceedings?
- Was petitioner’s warrantless arrest valid?
- Was there a valid inquest or preliminary investigation and were the proceedings that ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)