Case Summary (G.R. No. 64693)
Relevant Background
Estolano was apprehended by members of the Manila Police Department during a routine police operation known as "Oplan Sita." This operation involved flagging down vehicles for inspection, during which the police discovered the hand grenade in Estolano's possession. A corresponding Information was filed on May 4, 2015, charging him with violations under Presidential Decree No. 1866, as amended by Republic Act No. 9516 for possessing a dangerous explosive device without the requisite permits.
Prosecution’s Case
The prosecution's narrative details that around 6:15 a.m. on the date of the incident, police officers noticed a yellow Mitsubishi Lancer without a plate number and flagged it down for inspection. Upon approaching the vehicle, police officer PO3 Ruel Aguilar requested Estolano's identification and vehicle registration. Estolano's failure to produce these documents led the officers to conduct a body search, during which PO1 Sonny Boy Lubay observed him attempting to retrieve the pin of a hand grenade from his pocket. The grenade was subsequently confiscated, and various police officers involved confirmed the grenade's intact condition and explosive capability.
Defense's Claim
Estolano denied all allegations, claiming he was a victim of a frame-up. He recounted that he had attended a birthday party prior to the incident and was merely a passenger in the vehicle. He alleged that the police officers coerced him into confessing by administering physical force and that he was being unjustly targeted due to an inability to pay a bribe.
Decision of the Regional Trial Court (RTC)
The RTC found Estolano guilty of illegal possession of explosives, primarily relying on the testimonies of the police officers, which it deemed credible and consistent. The court denied Estolano's defense of frame-up, citing the presumption of regularity in police duties, and sentenced him to reclusion perpetua.
Appeal to the Court of Appeals (CA)
On appeal, Estolano questioned the credibility of the police officers' testimonies and suggested that the hand grenade should be inadmissible as evidence due to an unlawful warrantless search. The CA affirmed the RTC’s judgment and concluded that the prosecution had proven the essential elements of the crime, including the absence of a permit for possession of the hand grenade.
Legal Analysis of the Appeal
The Supreme Court reviewed the legalities surrounding the warrantless search conducted during the checkpoint operation. It established that routine traffic stops have limitations; any search must be justified by probable cause. The court cited precedent that traffic violations alone do not warrant extensive searches. Furthermore, it noted that the prosecution failed to present evidence establishing the legitimacy of the Oplan Sita operation or to justify the officers' actions beyond the vio
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Case Overview
- The appeal centers on the Decision dated September 27, 2018, made by the Court of Appeals (CA) in CA-G.R. CR-HC No. 07976.
- The CA upheld the Regional Trial Court (RTC) of Manila's prior conviction of Hermie Estolano y Castillo for violating Presidential Decree No. 1988, as amended by Republic Act No. 9516.
- Estolano was charged with illegal possession of a fragmentation grenade on or about April 17, 2015.
Charges and Context
- An Information was filed on May 4, 2015, alleging that Estolano possessed a MK2 Fragmentation Hand Grenade without the necessary license.
- The prosecution claimed that Estolano was aware of the explosive nature of the grenade and had it in his possession unlawfully.
Incident Details
- On April 17, 2015, police officers from the V. Mapa Police Station were conducting Oplan Sita when they flagged down a yellow Mitsubishi Lancer driven by Estolano.
- Upon being asked for his license and vehicle registration, Estolano failed to provide any documentation and initially refused to leave his vehicle.
- During a body search by PO1 Sonny Boy Lubay, Estolano was observed attempting to retrieve something from his pocket, which turned out to be the grenade.
Evidence and Recovery
- The grenade was subsequently marked and recorded by police investigators as part of the evidence collection process.
- A medical examination was conducted on Estolano before he was taken to the police station.
- A certification from the Firearms and Explosives Office confirmed that Estolano did no