GR 90319; (October, 1991) (Digest)
G.R. No. 90319 October 15, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARIO BRIONES, GERARDO JAVIER and EUSEBIO ALLIED, accused. MARIO BRIONES & GERARDO JAVIER, accused-appellants.
FACTS
Accused-appellants Mario Briones and Gerardo Javier were convicted by the Regional Trial Court of robbery with double homicide for the killing of spouses Felicisimo and Florencia Gutierrez and the taking of cash and jewelry from their home in San Simon, Pampanga, on April 23, 1988. The prosecution’s key witness, Pantaleon Francisco, testified that he saw the appellants and their co-accused mauling Florencia Gutierrez outside her house before dragging her inside. The following morning, the spouses were found dead. Based on Francisco’s identification, police apprehended Briones in Malabon, where jewelry belonging to the victims was found in his possession. Javier was later arrested in Taguig.
ISSUE
The core issues are whether the warrantless arrests of the appellants were legal and whether the evidence obtained against them is admissible despite alleged violations of their constitutional rights during custodial investigation.
RULING
The Supreme Court affirmed the conviction but modified the indemnity. It ruled that the warrantless arrests were indeed illegal, as they did not fall under the recognized exceptions under Rule 113, Section 5 of the Rules of Court. The arresting officers had no personal knowledge of the appellants having just committed the offense; they relied on information from eyewitness Francisco. However, the Court held that the appellants effectively waived any objection to the illegality of their arrest by failing to raise it before arraignment and by voluntarily entering a plea. Citing De Asis v. Romero, the Court emphasized that objections to jurisdiction over the person must be raised opportunely; otherwise, they are deemed waived. Furthermore, the conviction was sustained based on the overwhelming evidence of guilt, principally the positive eyewitness identification by Francisco, which was found credible and consistent. The Court deemed it impractical to nullify the proceedings given the waiver and the strength of the evidence. The constitutional rights argument was rendered moot by this finding on waiver and the independent evidence of guilt.