G.R. No. 97143 October 2, 1995
People of the Philippines, plaintiff-appellee, vs. Arturo Figueroa, accused-appellant.

FACTS

Accused-appellant Arturo Figueroa was charged with Illegal Possession of Firearm and Ammunition. On November 10, 1989, PC officers led by Capt. Lodivino Rosario arrived at Figueroa’s residence in Cavite to serve a warrant for his arrest issued by a Makati court for unrelated drug and ammunition charges. While inside the house to effect the arrest, the officers noticed aluminum foil packages strewn in the sala, suspecting the presence of “shabu.”
The arresting officers then requested Figueroa and his siblings to consent to a search of the premises. The subsequent search yielded a .45 caliber pistol with a defaced serial number, a magazine, seven live ammunitions, and a matchbox containing shabu. Figueroa denied ownership of these items. An inventory was conducted and attested to by the barangay captain.

ISSUE

The core issue is whether the .45 caliber pistol and ammunition seized during the warrantless search are admissible as evidence against the accused.

RULING

The Supreme Court affirmed the conviction, ruling the evidence was lawfully obtained. The Court held that the warrantless search and seizure were valid as an incident to a lawful arrest. The officers were legitimately inside the accused’s premises to serve a valid arrest warrant. Objects in “plain view” of an officer who has a right to be in that position are subject to seizure.
While the Court noted difficulty in readily accepting that consent for the search was freely given, it emphasized that the search was incidental to the lawful arrest. The rule allows a warrantless search extending beyond the person arrested to include the premises under his immediate control. The firearm and ammunition, found within such premises, were therefore admissible.
The Court also found no merit in the appellant’s challenges to witness credibility, dismissing alleged inconsistencies in the officers’ testimonies regarding minor details like the accused’s exact location or the gun’s precise placement as natural variations in perception. The claim of a “frame-up” was rejected due to the appellant’s failure to report the allegation promptly and the presumption of regularity in the performance of official duty in the absence of strong contrary evidence.