Title
Padilla vs. Court of Appeals
Case
G.R. No. 121917
Decision Date
Mar 12, 1997
Robin Padilla convicted for illegal possession of firearms after a lawful arrest; Supreme Court upheld conviction but reduced penalty due to insufficient evidence of permits.

Case Summary (G.R. No. 121917)

Petitioner

Robin C. Padilla @ Robinhood Padilla

Respondents

Court of Appeals; People of the Philippines

Key Dates

• October 26, 1992 – Hit-and-run incident; discovery of firearms.
• December 3, 1992 – Information filed for illegal possession of firearms under P.D. 1866.
• April 25, 1994 – RTC conviction: indeterminate penalty (17 y 4 m 1 d to reclusion perpetua).
• July 21, 1995 – CA decision affirming conviction and canceling bail.
• March 12, 1997 – Supreme Court decision under review.

Applicable Law

• 1987 Philippine Constitution (decision post-1990).
• P.D. 1866 – Unlawful possession of firearms and ammunition.
• Rule 113, Sec. 5, and Rule 126, Sec. 12 of the Rules of Criminal Procedure.
• Jurisprudence on warrantless arrest, search‐seizure exceptions, exclusionary rule, indeterminate penalties.

Factual Background

Petitioner’s Pajero allegedly hit a balut vendor. Manarang, a private bystander, heard the collision, saw the victim, reported via radio to PNP, and pursued the vehicle. At Abacan Bridge, PNP officers SPO2 Borja and SPO2 Miranda intercepted the Pajero, identified Petitioner as driver, and observed a revolver at his waist (plain view). A rifle magazine protruded from his back pocket. Subsequent search of the vehicle revealed an M-16 “Baby Armalite” rifle; Petitioner later surrendered a Beretta .380 pistol and additional magazines.

Procedural History

RTC of Angeles City convicted Petitioner of illegal possession of firearms and ammunition under P.D. 1866, sentencing him to an indeterminate penalty. He appealed; the CA affirmed the conviction, canceled bail, and ordered his arrest. Petitioner filed motions for reconsideration, supplemental petitions, and an application for bail in the Supreme Court, which were denied. The Solicitor-General ultimately filed a manifestation seeking acquittal, but the Court resolved on a certificate of review under Rule 45.

Issues

  1. Legality of warrantless arrest and admissibility of seized firearms and ammunition.
  2. Validity of Petitioner’s claimed authorization via Mission Order and Memorandum Receipt.
  3. Constitutionality and excessiveness of the penalty under P.D. 1866.

Legality of Arrest

• Warrantless arrest is lawful when an offense is committed in the presence of a private person (Rule 113, Sec. 5(a)). Manarang personally witnessed and pursued the hit-and-run vehicle.
• PNP officers acted promptly upon verified radio information and their own observation (dangling plate, dented hood), satisfying “personal knowledge” under Sec. 5(b).
• Exigent circumstances (hot pursuit, moving vehicle, public place at night) justified immediate arrest without a warrant.
• No timely motion to quash or pre-plea objection was filed; Petitioner is estopped from belatedly challenging the arrest.

Admissibility of Firearms and Ammunition

• Plain-view seizure: Officers lawfully present and inadvertently observed the revolver at the waist and magazine in pocket upon alighting.
• Search incidental to lawful arrest: The vehicle was within Petitioner’s area of control; a protective sweep and inventory were contemporaneous.
• Search of a moving vehicle exception: Mobility reduced privacy expectation; probable cause existed that Petitioner was engaged in criminal activity.
• Voluntary surrender: The Beretta and additional magazines were freely handed over, waiving any right to object.

Mission Order and Memorandum Receipt Defense

• Two elements of illegal possession: possession of firearm (proven) and lack of valid permit (proven).
• Petitioner presented Mission Order and Memorandum Receipt issued by a deputy commander, not authorized under PNP guidelines (only Unit Commanders or Chiefs).
• Documents were created after arrest, not produced at preliminary investigation or trial; Petitioner never testified or offered them timely.
• PNP Firearms and Explosives Office certification establishes that the subject firearms were not registered in Petitioner’s name.

Constitutionality and Pe




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