GR 213225; (April, 2018) (Digest)
G.R. No. 213225 APRIL 4, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs RENANTE COMPRADO Y BRONOLA, Accused-Appellant
FACTS
Accused-appellant Renante Comprado was charged with illegal possession of marijuana under R.A. 9165. The prosecution alleged that based on a tip from a confidential informant (CI), police established a checkpoint in Cagayan de Oro City. They stopped a bus, found Comprado matching the CI’s description with a backpack on his lap, and upon inspection, discovered 3,200 grams of marijuana inside. The police marked the seized items at the scene and later had them examined, confirming the substance was marijuana.
Comprado presented a different version, claiming he was arrested earlier in Malaybalay City, Bukidnon, during a baggage inspection of a different vehicle. He denied ownership of the bag, stating he was merely asked by a debtor to transport it to Cagayan de Oro. The Regional Trial Court and the Court of Appeals convicted him, giving credence to the police narrative and ruling that his warrantless arrest was valid.
ISSUE
Whether the warrantless arrest of the accused-appellant was valid, thereby rendering the seized drugs admissible as evidence.
RULING
No. The Supreme Court reversed the conviction and acquitted Comprado. The Court held that the warrantless arrest was invalid, making the subsequent search and seizure unlawful. For a valid warrantless arrest under Rule 113, Section 5(b) of the Rules of Court, the arresting officer must have personal knowledge of facts indicating that the person to be arrested has just committed, is actually committing, or is attempting to commit an offense. Here, the police acted solely on the information from a confidential informant. They had no prior personal knowledge or direct observation of any criminal activity by Comprado. The tip alone did not provide the requisite personal knowledge to justify an arrest without a warrant.
Consequently, the marijuana seized during the illegal arrest is inadmissible as evidence under the exclusionary rule. The prosecution’s case crumbled as the corpus delicti was obtained in violation of Comprado’s constitutional right against unreasonable searches and seizures. An acquittal is warranted because the State failed to prove his guilt beyond reasonable doubt with lawful evidence. The Court emphasized that an accused’s failure to object to an illegal arrest before arraignment constitutes a waiver only of any jurisdictional defect over his person, not a waiver of the inadmissibility of evidence seized from an unlawful arrest.