G.R. No. 132671 ; November 15, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CRISANTO BAULA, RUBEN BAULA, ROBERT BAULA and DANILO DACUCOS, accused-appellants.

FACTS

The accused-appellants were charged with the murder of Patrocenia Caburao on December 13, 1995, in Sual, Pangasinan. The prosecution’s primary witness, Jupiter Caburao, the victim’s son, testified that while following his mother that evening, he used a flashlight and saw appellants Crisanto Baula and Danilo Dacucos hacking a person on the ground, while Robert Baula and Ruben Baula acted as lookouts. Fearing reprisal, Jupiter did not immediately report the incident. Police investigation led them to the appellants. Without a warrant, police officers went to the houses of the appellants. Ruben Baula and Crisanto Baula allegedly voluntarily surrendered bloodstained clothing, and a bloodstained bolo was found in Danilo Dacucos’s hut. Forensic tests showed the blood on these items matched the victim’s blood type.
The defense presented a different account. Barangay Captain Wilson Radovan testified he heard cries for help and later found the victim’s body, with no assailants in sight. Ruben Baula claimed he and his co-accused were harvesting palay and later had merienda at a store, leaving before the victim, and were asleep when arrested. They denied any involvement in the killing and contested the voluntariness of the surrender of the evidence.

ISSUE

The core issue is whether the warrantless arrests of the accused-appellants and the subsequent seizure of the bloodstained evidence were valid under the law, and if not, whether the evidence obtained is admissible.

RULING

The Supreme Court reversed the conviction and acquitted all accused-appellants. The Court held that the warrantless arrests were invalid. Arrests without a warrant are only permissible under specific circumstances outlined in Rule 113, Section 5 of the Rules of Court, such as when the person to be arrested has committed, is actually committing, or is attempting to commit an offense in the presence of the arresting officer. None of these conditions were present here. The police arrested the appellants based merely on suspicion and their presence at the store where the victim was last seen, which does not constitute probable cause for a warrantless arrest.
Consequently, the seizure of the bloodstained clothing and bolo was also illegal. The Court rejected the prosecution’s claim that the items were voluntarily surrendered, finding this less than credible. The presumption of regularity in the performance of official duty cannot prevail over the constitutional rights against unreasonable searches and seizures. The evidence obtained was the “fruit of the poisonous tree” and therefore inadmissible. Without this illegally obtained physical evidence, and with the eyewitness testimony deemed insufficient to establish guilt beyond reasonable doubt, the prosecution’s case collapsed. The Court emphasized that while the pursuit of criminals is essential, it cannot justify the use of arbitrary methods that violate constitutional protections.