G.R. No. 245921 . October 05, 2020
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ABDILLAH PANGCATAN Y DIMAO, ACCUSED-APPELLANT.

FACTS

Accused-appellant Abdillah Pangcatan was charged with Murder for the shooting death of Richelle Anne Marabe on January 9, 2015, and with Illegal Possession of Firearm and Ammunition and Illegal Possession of Explosives based on items seized from him upon his arrest on January 11, 2015. The prosecution’s eyewitness, Renante Cruz, claimed to have witnessed the shooting from a distance. He later identified Pangcatan from photo albums at the police station and subsequently in a police lineup. Following this identification, police officers arrested Pangcatan and conducted a body search, which yielded a .45 caliber pistol, ammunition, and a hand grenade. Pangcatan filed a Motion to Quash and to Suppress Evidence, arguing his warrantless arrest was illegal, rendering the search incidental thereto invalid. The Regional Trial Court denied the motion.

ISSUE

The core issue is whether the warrantless arrest of Pangcatan was lawful, thereby validating the subsequent search and seizure of the firearm, ammunition, and explosive.

RULING

The Supreme Court ruled that the warrantless arrest was unlawful. For a valid warrantless arrest under Section 5(b), Rule 113 of the Rules of Court, the arresting officer must have personal knowledge of facts indicating that the person to be arrested has committed a crime. Here, the arresting officers had no such personal knowledge. Their reliance was solely on the identification made by Renante Cruz during the police lineup. The Court emphasized that information provided by another person, even an eyewitness, does not constitute the “personal knowledge” required by the rule for an arrest in flagrante delicto. The police orchestrated the lineup, effectively inviting Pangcatan to the station, which negates any notion of a hot pursuit arrest. Consequently, the arrest being unlawful, the search incidental thereto was likewise invalid. All evidence obtained—the firearm, ammunition, and hand grenade—must be excluded as “fruit of the poisonous tree.” The charges for Illegal Possession of Firearm and Ammunition and Illegal Possession of Explosives were dismissed. However, the Court affirmed the conviction for Murder. The illegality of the arrest does not affect the court’s jurisdiction over the murder charge. The positive identification by the eyewitness, whose credibility was upheld by the trial court, sufficiently established Pangcatan’s guilt for Murder beyond reasonable doubt.