Title
Porteria y Manebali vs. People
Case
G.R. No. 233777
Decision Date
Mar 20, 2019
Motorcycle theft case: Marvin acquitted due to illegal search, inadmissible confession, and insufficient evidence linking him to the crime.

Case Summary (G.R. No. 233777)

Factual background and operative events

Christian parked his 2004 blue Honda motorcycle along Panganiban Drive, Naga City, and later discovered it missing. He reported the theft to the local police and completed the necessary documents. On February 1, 2011, police in Ocampo received a tip about a suspicious person and subsequently apprehended Marvin; during the arrest or related processing officers discovered a bag containing photocopies of the motorcycle’s OR and CR. Marvin was later alleged to have told police the motorcycle was with a “Felix” in Sta. Rosa, Laguna; he also allegedly told Virgie (Christian’s mother) that he had taken the motorcycle and left it with another person in Sta. Rosa. On March 11, 2011, a checkpoint in Barangay Kaingin, Sta. Rosa resulted in the recovery of a blue motorcycle driven by Albert Orino, who stated that Marvin had left the motorcycle with him. Marvin was not present when the motorcycle was intercepted.

Procedural history

An Information charging Marvin and co-accused Albert and Felix with violation of R.A. No. 6539 was filed October 27, 2011. Marvin pleaded not guilty; the RTC of Naga City, Branch 26, conducted trial and, on December 5, 2014, convicted Marvin for carnapping and sentenced him to imprisonment. Marvin appealed to the Court of Appeals, which on May 12, 2017 affirmed the conviction (with a minor modification of sentence), and denied reconsideration on August 16, 2017. Marvin filed a petition for review on certiorari under Rule 45 before the Supreme Court, which granted the petition and acquitted him on March 20, 2019.

Issues presented to the Supreme Court

The petition challenged: (1) the legality of the search and seizure that produced the motorcycle’s OR and CR from Marvin’s bag and person, arguing the search was not a valid incident-to-arrest or otherwise lawful; and (2) the admissibility and voluntariness of Marvin’s alleged oral admissions/extrajudicial confessions (both to police and to the complainant’s mother), contending his rights to remain silent and to counsel were violated.

Trial court and Court of Appeals findings relied upon by the prosecution

Both lower courts convicted on circumstantial evidence. Their key factual inferences were: the discovery of the motorcycle registration documents in Marvin’s possession at arrest; Marvin’s alleged voluntary statement to P/Insp. Villamer that the motorcycle was with Felix; Virgie’s testimony recounting Marvin’s confession to her that he took the motorcycle and left it in Sta. Rosa; and the recovery of the motorcycle in Sta. Rosa. The courts treated these circumstances as an unbroken chain sufficient to satisfy the Rules of Court standard for circumstantial evidence.

Constitutional and evidentiary standards invoked by the Supreme Court

Because the decision postdates 1990, the Supreme Court applied the 1987 Constitution. The Court emphasized the constitutional guarantee against unreasonable searches and seizures (Article III, Section 2) and the right of persons under custodial investigation to be informed of the right to remain silent and to counsel (Article III, Section 12), as implemented by R.A. No. 7438. The Court reiterated that warrantless searches are presumptively unreasonable unless they fall within recognized exceptions (including search incidental to a lawful arrest, plain view, moving vehicle, consent, customs, stop-and-frisk, and exigent circumstances). For a search-incident-to-arrest exception, the legality of the search depends on the legality of the arrest; warrantless arrests are valid only under the circumstances enumerated in Rule 113, Section 5 (in flagrante delicto, personal knowledge/probable cause based on the arresting officer’s observation or hot pursuit, or escaped prisoner).

Analysis of the legality of the arrest and search

The Court found the prosecution failed to prove a lawful basis for a warrantless arrest of Marvin under Rule 113, Section 5. Testimony showed only that police acted on an anonymous tip of a “suspicious person,” without specification of any overt act by Marvin that would satisfy the in flagrante delicto test (overt act committed in the officer’s presence) or establish the arresting officers’ personal knowledge of facts indicating a just‑committed offense (hot pursuit). SPO4 Pequiras did not describe any act by Marvin that would have made him identifiable as the suspicious person or show Marvin had a firearm visibly tucked in his waist. Because the arrest was not shown to be lawful, any search incident to that arrest was likewise invalid. The Court further held that the stop‑and‑frisk exception did not apply: a valid stop‑and‑frisk requires specific, articulable facts constituting more than mere suspicion (a “genuine reason” based on overt acts and surrounding circumstances), which were absent here.

Admissibility of the OR and CR seized from Marvin and the exclusionary rule

Because the search that produced the OR and CR was unlawful, the Court applied the exclusionary rule and ruled the registration documents inadmissible. The Court declined to treat the waiver doctrine or failure to object in trial as salvaging the improperly obtained evidence; even if an accused participates in proceedings without objecting to arrest validity, the Court may still exclude evidence obtained by an illegal arrest or search. Consequently, the OR and CR could not be relied upon as part of the prosecution’s circumstantial chain.

Admissibility and voluntariness of Marvin’s alleged admissions and extrajudicial confessions

The Court distinguished Marvin’s alleged statements to police from the alleged statement to Virgie (a private party). Marvin’s statement to P/Insp. Villamer occurred after he was in custody and should have been preceded by Miranda‑type warnings and counsel assistance per Article III, Section 12 and R.A. No. 7438. The record contained no testimony that Marvin was informed of his rights or that he waived them in writing and in counsel’s presence. Therefore Marvin’s “voluntary” statement to police was inadmissible. As to the oral confession to Virgie, while not within the strict statutory formalities that govern confessions to police, an extrajudicial confession must still be shown to be voluntary and reliable; here the only evidence of that statement was Virgie’s t

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