Case Digest (G.R. No. 191699) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Bryan Ta-ala y Constantino vs. People of the Philippines (G.R. No. 254800, June 20, 2022), petitioner Bryan Ta-ala y Constantino was arrested without a warrant on August 6, 2016 in Bacolod City by officers of the Criminal Investigation and Detection Group (CIDG). According to the arresting officers’ Affidavit of Arrest, they received intelligence from U.S. Homeland Security and the Philippine Bureau of Customs that a shipment of firearms and accessories would arrive at Atlas Shippers International. Posing as errand boys, SPO4 Liberato S. Yorpo and SPO1 Jerome G. Jambaro alleged they saw petitioner step out of a Toyota Hilux and—both from his waistband and inside a package he claimed with Wilford Palma y Zarceno (alias Michael Diamante)—a Glock 26 9mm pistol (SN ELR043) and numerous firearm parts. An inquest was conducted by Assistant State Prosecutor Michael A. Vito Cruz, who, in two resolutions, found probable cause for multiple violations of R.A. 10591 (illegal possession a Case Digest (G.R. No. 191699) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Warrantless Arrest and Seizure
- On August 6, 2016, SPO4 Yorpo and SPO1 Jambaro of CIDG-Negros Occidental arrested Bryan Ta-ala y Constantino (petitioner) and Wilford Palma y Zarceno without a warrant at an Atlas Shippers office in Bacolod City.
- In their Affidavit of Arrest (executed August 8, 2016), the officers claimed they saw a Glock 26 9mm pistol (SN ELR043) tucked in petitioner’s waist and, simultaneously, found the same pistol plus assorted firearm accessories inside a package petitioner’s companion had retrieved.
- Inquest Proceedings and Informations Filed
- On August 8, 2016, a Letter-Complaint was filed in DOJ Inquest Docket XVI-INQ-16H-00110; ASP Vito Cruz conducted an inquest, issuing on August 22, 2016 a resolution finding probable cause to charge petitioner with two counts under Section 28, RA 10591 (illegal possession of firearm and accessories).
- On September 13, 2016, ASP Vito Cruz issued another resolution finding probable cause for Section 33, RA 10591 (arms smuggling) and Sections 101(a)/3601, Tariff and Customs Code (smuggling). Four separate informations ensued before RTC-Branches 46, 50, 54, and 42 (the latter two later withdrawn).
- Trial Court and Court of Appeals Dispositions
- Petitioner filed motions to quash the informations, suppress evidence, consolidate cases, and post bail—all denied by RTC-Branches 46 and 54. He posted bail yet remained detained pending preliminary investigation.
- He filed two certiorari petitions with the Court of Appeals (CA-G.R. SP 10697 and CA-G.R. SP 10873) challenging the denial of his motions; the CA consolidated and dismissed both petitions on May 9, 2019, and denied reconsideration on January 30, 2020.
Issues:
- Whether petitioner’s warrantless arrest and the incidental search were lawful.
- Whether the inquest and further proceedings complied with Article 125, RPC, and the Revised Rules of Criminal Procedure.
- Whether evidence seized during the arrest and search is admissible.
- Consequences of any illegality on the pending criminal cases.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)