GR 170233; (February, 2007) (Digest)
G.R. No. 170233 ; February 22, 2007
The People of the Philippines, Appellee, vs. Jesus Nuevas y Garcia, Reynaldo Din y Gonzaga, and Fernando Inocencio y Abadeos, Appellants.
FACTS
Appellants were convicted for illegal possession of marijuana. The prosecution’s narrative, from PO3 Fami and SPO3 Cabling, states that based on a tip, they conducted surveillance and accosted Jesus Nuevas, who matched an informant’s description, along Perimeter Street. Nuevas allegedly voluntarily pointed to a plastic bag containing marijuana and later led the officers to Purok 12, Old Cabalan, where they apprehended Reynaldo Din and Fernando Inocencio. Din was allegedly carrying a bag containing marijuana, which he voluntarily surrendered. The defense presented a starkly different version. Nuevas claimed he was arbitrarily arrested, robbed, and forced to carry a plastic bag. Din and Inocencio testified they were arrested inside Din’s house without explanation and only met Nuevas in jail, denying any knowledge of or possession of marijuana.
ISSUE
The core issue is whether the warrantless arrests and consequent seizures of marijuana from the appellants were valid, rendering the confiscated evidence admissible.
RULING
The Supreme Court acquitted all appellants, finding the arrests illegal and the evidence inadmissible. For Nuevas, the arrest was not lawful under Rule 113, Section 5(a). The police had no personal knowledge that he was committing a crime at the moment they accosted him; their information was a mere tip, not amounting to probable cause for a warrantless arrest. The subsequent search yielding marijuana was therefore invalid. For Din and Inocencio, their arrest was likewise invalid. The police acted solely on Nuevas’s uncorroborated information, which did not constitute personal knowledge of a crime being committed by Din and Inocencio in the officers’ presence. The alleged voluntary surrender of the bag was deemed incredible given the illegal arrest. Consequently, the marijuana seized from all three was the “fruit of the poisonous tree.” With the evidence obtained in violation of constitutional rights against unreasonable searches and seizures, the prosecution’s case collapsed. The guilt of the appellants was not proven beyond reasonable doubt, necessitating their acquittal.