G.R. No. 242889. March 14, 2022.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. LENG HAIYUN, DANG HUIYIN, LIU WEN XION A.K.A. “LUI XIN,” AND LEI GUANG FENG, ACCUSED-APPELLANTS.

FACTS

On May 28, 2013, at around 6:30 PM, Michael Claveria, a gasoline boy at the North Metro Oil Gasoline Station in Pasuquin, Ilocos Norte, reported to the police that a silver gray Toyota Previa was parked at the station and that someone from it had broken two bottles. Police officers followed Claveria back to the station. Upon seeing the police, the occupants of the Toyota Previa (later identified as accused-appellants Leng Haiyun, Dang Huiyin, Liu Wen Xion, and Lei Guang Feng) fled. The police gave chase. Police Inspector Joseph Tayaban contacted officers at a nearby COMELEC checkpoint in Barangay Davila to intercept the vehicle. At the checkpoint, PI Tayaban approached the vehicle and saw four foreigners and around six pieces of plate numbers scattered on the floor. Accused-appellants could not present passports or entry documents. After a phone conversation with a woman named “Candy” who requested their release, PI Tayaban instructed the occupants to follow the patrol car to the station. PI Tayaban later boarded their vehicle to prevent escape. At the police station, as accused-appellants alighted, police officers saw, in plain view, several butts and barrels of firearms under the second-row seat. The area was cordoned, and accused-appellants were handcuffed. A subsequent search of the vehicle, conducted in the presence of accused-appellants, barangay officials, and media, yielded firearms, explosives, and ammunition. Accused-appellants were charged with illegal possession of explosives, illegal possession of firearms, and violation of the election gun ban. They pleaded not guilty, claiming the items were not found inside their vehicle but were first seen on a table outside the station. The Regional Trial Court convicted them for illegal possession of explosives and violation of the election gun ban but dismissed the charge for illegal possession of firearms. The Court of Appeals affirmed the conviction. Accused-appellants appealed to the Supreme Court.

ISSUE

Whether the warrantless arrest of accused-appellants and the subsequent warrantless search and seizure of the firearms and explosives were valid.

RULING

Yes, the warrantless arrest was valid as a “hot pursuit” arrest under Rule 113, Section 5(b) of the Rules of Court. The police officers had personal knowledge of facts and circumstances, based on a confluence of events, that gave them probable cause to believe accused-appellants had committed an offense. The circumstances included: (1) the report from the gasoline boy about the suspicious vehicle and bottle-breaking incident; (2) the immediate police investigation at the scene; (3) the flight of accused-appellants upon seeing the police, which reinforced suspicion; (4) the chase; and (5) the interception at the COMELEC checkpoint. The subsequent search was also valid as a search incidental to a lawful arrest. The firearms and explosives were discovered in plain view when accused-appellants alighted from the vehicle at the police station, which was within the permissible scope of a search incident to arrest. The chain of custody of the seized items was also established. Therefore, the Supreme Court affirmed the decision of the Court of Appeals, upholding the conviction of accused-appellants for illegal possession of explosives under Section 3 of P.D. No. 1866 and for violation of the election gun ban under COMELEC Resolution No. 9561-A in relation to Section 261(q) of B.P. Blg. 881.