G.R. No. 248529 , April 19, 2023
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. MARK ALVIN LACSON Y MARQUESSES A.K.A “MAC-MAC”, NOEL AGPALO Y SACAY AND MOISES DAGDAG Y CORPUZ, ACCUSED, MARK ALVIN LACSON Y MARQUESSES A.K.A “MAC-MAC” AND NOEL AGPALO Y SACAY, ACCUSED-APPELLANTS.

FACTS

On October 7, 2013, police officers patrolling as part of “Oplan Sita” in Taguig City received a text message about a snatching incident. They proceeded to the area and saw three male individuals, accused-appellants Mark Alvin Lacson and Noel Agpalo, along with Moises Dagdag, who appeared suspicious and attempted to run. The officers intercepted and accosted them. Upon apprehension, PO2 Paparon felt a hard object on Agpalo’s waist, which turned out to be a loaded paltik revolver. Agpalo failed to produce a license. PO1 Valdez frisked Lacson and recovered a hand grenade, for which Lacson also failed to produce any authorization. Dagdag was apprehended by another officer. Separate Informations were filed against them for illegal possession of explosives (Lacson), illegal possession of firearms and ammunition (Agpalo), and violation of the election gun ban (all three). They pleaded not guilty. The defense claimed they were merely on their way home, were wrongfully arrested, and that the evidence was planted after they were lured to the police station and mauled. The Regional Trial Court convicted Lacson and Agpalo but acquitted Dagdag due to the prosecution’s failure to prove his guilt. The Court of Appeals affirmed the convictions. Lacson and Agpalo appealed to the Supreme Court, arguing their warrantless arrests were illegal and the evidence obtained was inadmissible.

ISSUE

Whether the warrantless arrests of Lacson and Agpalo were valid and whether the evidence (hand grenade and firearm) seized from them is admissible.

RULING

The Supreme Court denied the appeal and affirmed the convictions. The Court held that while the warrantless arrests were invalid for not falling under the instances allowed under Rule 113, Section 5 of the Rules of Court (i.e., they were not committing, had just committed, or were attempting to commit an offense in the presence of the arresting officers), the accused-appellants are estopped from questioning the legality of their arrest because they failed to raise this objection before their arraignment. This failure is deemed a waiver of any irregularity in their apprehension for the purpose of vesting the court with jurisdiction over their persons. However, the Court clarified that the waiver of the right to question an illegal arrest does not extend to the right to contest the admissibility of evidence obtained from an unlawful search. The evidence—the hand grenade and the firearm—were seized as a direct result of the invalid warrantless arrests and the subsequent searches incidental thereto. Since the arrests were unlawful, the searches were likewise invalid, and the seized items are inadmissible as “fruits of the poisonous tree.” Consequently, without the inadmissible evidence, the prosecution failed to prove the guilt of Lacson and Agpalo beyond reasonable doubt. The Court reversed the Court of Appeals Decision and acquitted accused-appellants Mark Alvin Lacson and Noel Agpalo on the ground of reasonable doubt.