Padilla vs. Court of Appeals

Owner of Illegal Firearms (D) vs. the Government (P)
GR 121917, March 12, 1997 (269 SCRA 414)	[T][T]

Summary: In response to a hit-and-run accident reported by an eyewitness, the police was able to catch up with and apprehend the driver fleeing the scene and discovered several firearms in the vehicle in plain view.

Rule of Law: A peace officer or a private person may, without a warrant, arrest a person when an offense has in fact just been committed, and he has personal knowledge of facts indicating that the person to be arrested has committed it. Objects whose possession are prohibited by law inadvertently found in plain view are subject to seizure even without a warrant.

Facts: At 8:00pm, Maranarag and his companion witnessed a hit-and-run accident involving the Mitsubishi Pajero of Robin Padilla (D), who was the unknown driver at the time. As a member of a civic group, Maranarag decided to report the incident to the police via VHF radio. Mobile patrols responded and chased the fleeing Pajero to the north. They finally caught up with the Padilla (D) and found several firearms in the vehicle and in his person.

Issues: Is the warrantless arrest valid? Is the warrantless search valid?

Ruling: Yes. The Court acknowledges police authority to make the forcible stop since they had more than mere "reasonable and articulable" suspicion that the occupant of the vehicle has been engaged in criminal activity after the hit-and-run incident was reported to them. Thus, the warrantless arrest was proper as Padilla (D) was caught in flagrante delicto with possession of unlicensed firearms and ammunition.