G.R. No. 182601 , November 10, 2014
JOEY M. PESTILOS, DWIGHT MACAPANAS, MIGUEL GACES, JERRY FERNANDEZ and RONALD MUNOZ v. MORENO GENEROSO and PEOPLE OF THE PHILIPPINES

FACTS

On February 20, 2005, at around 3:15 a.m., an altercation ensued between the petitioners and Atty. Moreno Generoso at Kasiyahan Street, Barangay Holy Spirit, Quezon City. Atty. Generoso reported the incident to the police. SPO2 Dominador Javier, together with augmentation personnel, arrived at the scene less than an hour later and saw Atty. Generoso badly beaten. Atty. Generoso pointed to the petitioners as his assailants. The police officers then “invited” the petitioners to the Batasan Hills Police Station for investigation, and the petitioners went with them. After an inquest proceeding, the City Prosecutor found that the petitioners stabbed Atty. Generoso with a bladed weapon, and an Information for attempted murder was filed against them on February 22, 2005. The petitioners filed an Urgent Motion for Regular Preliminary Investigation, arguing that they were not lawfully arrested without a warrant since they were merely “invited” and the police had no personal knowledge of the crime. The Regional Trial Court (RTC) denied the motion, a decision affirmed by the Court of Appeals (CA). The petitioners elevated the case to the Supreme Court.

ISSUE

1. Whether the petitioners were validly arrested without a warrant.
2. Whether the petitioners were lawfully arrested when they were merely “invited” to the police precinct.
3. Whether the RTC Order denying the motion for preliminary investigation is void for failure to state the facts and the law upon which it was based.

RULING

The Supreme Court denied the petition and upheld the RTC Order.
1. On the validity of the warrantless arrest: The Court ruled that a valid warrantless arrest under Section 5(b), Rule 113 of the Rules of Court occurred. The police officers, responding to a report, arrived at the crime scene less than an hour after the altercation, which qualifies as the offense having “just been committed.” Atty. Generoso, the victim, was present and pointed to the petitioners as the perpetrators. This provided the arresting officers with “probable cause based on personal knowledge of facts or circumstances” that the petitioners committed the offense. The Court clarified that “personal knowledge” for a warrantless arrest under this provision includes knowledge derived from the personal perception of the victim or eyewitnesses who point to the offender at the scene.
2. On the nature of the “invitation”: The Court held that the use of the word “invited” in the Affidavit of Arrest did not negate the fact of a lawful arrest. The circumstances showed that the police officers’ “invitation” was a command in the context of effecting an arrest. The petitioners voluntarily went with the officers, which did not invalidate the arrest as they were already validly arrested under the warrantless arrest rule.
3. On the validity of the RTC Order: The Court found that the RTC Order denying the Urgent Motion for Regular Preliminary Investigation sufficiently explained its grounds. It stated that the motion was denied because the petitioners were lawfully arrested without a warrant, making the inquest proceeding proper. This compliance with the requirement to state the legal basis was adequate.
The Court concluded that the warrantless arrest was valid, the subsequent inquest proceeding was proper, and the criminal proceedings against the petitioners should proceed.