**Facts:**
This case began with the arrest and subsequent conviction of Martin Villamor and Victor Bonaobra for violations of Presidential Decree (PD) No. 1602 as amended by Republic Act (RA) No. 9287, otherwise known as the law increasing penalties for illegal numbers games. Villamor was convicted as a collector of bets, and Bonaobra as a coordinator, controller, or supervisor of the illegal numbers game known as “lotteng.” Their convictions were based on an operation conducted by the police, who had received a tip and proceeded to Bonaobra’s residence without a warrant, where they claimed to have observed illegal gambling activities. Villamor and Bonaobra challenged these convictions on appeal, claiming violations of their constitutional rights against unreasonable searches and seizures. Previously, their motions for reinvestigation and amended charges were granted, yet they were still convicted by the Regional Trial Court (RTC) and the Court of Appeals (CA) affirmed the RTC’s decision. This brought the case before the Supreme Court for final review.
**Issues:**
1. Whether the petitioners’ right against unreasonable searches and seizures was violated.
2. Whether the evidence obtained from the warrantless search was admissible.
3. Whether the petitioners’ actions at the time of arrest constituted a valid in flagrante delicto warrantless arrest.
**Court’s Decision:**
The Supreme Court found the petition to be meritorious. It held that the arrest and search conducted by the police were unlawful as they violated the constitutional protection against unreasonable searches and seizures, given that they entered Bonaobra’s compound without a valid warrant. The Court ruled that since the warrantless arrest did not satisfy the elements of a lawful in flagrante delicto arrest, and because the evidence was obtained through an unlawful search, it was inadmissible. Consequently, without the evidence, the convictions could not be upheld, leading to the acquittal of Villamor and Bonaobra.
**Doctrine:**
The decision reiterates the doctrine against unreasonable searches and seizures, emphasizing that evidence obtained as a result of a constitutional violation is inadmissible in any proceeding. It also outlines the requirements for a lawful in flagrante delicto arrest, clarifying that without direct, personal observation of a criminal act, an arrest and any subsequent search and seizure are invalid.
**Class Notes:**
– The constitution prohibits unreasonable searches and seizures, requiring a valid warrant unless specific exceptions apply.
– An in flagrante delicto warrantless arrest requires the perpetrator to have just committed, be committing, or be about to commit an offense in the presence of the arresting officer.
– Evidence obtained through a violation of this constitutional protection is inadmissible in court (“fruit of the poisonous tree” doctrine).
– A waiver of an illegal warrantless arrest does not imply a waiver on the inadmissibility of evidence seized during such an arrest.
**Historical Background:**
This case underscores the judiciary’s steadfast guard over constitutional rights, particularly against unreasonable searches and seizures, even in the pursuit of criminal enforcement. It reemphasizes the necessity for law enforcement to adhere strictly to procedural requirements to protect the rights of individuals, ensuring that convictions are made based on legally obtained evidence. This decision comes in a line of jurisprudence prioritizing constitutional protections over expedient law enforcement tactics that disregard legal procedures.
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