### **Facts:**
Herofil N. Olarte was convicted by the Regional Trial Court (RTC) of Cagayan de Oro City, Misamis Oriental, for illegal possession of a hand grenade under Republic Act (RA) No. 9516, an amendment to Presidential Decree (P.D.) No. 1866, and acquitted of illegal possession of a replica firearm under RA No. 10591. The conviction was affirmed by the Court of Appeals (CA), leading to an appeal to the Supreme Court (SC).
**Procedural Posture:**
1. July 19, 2014: Olarte was arrested for possessing an M61 fragmentation grenade and a .25 caliber pistol replica, following a police operation in Cagayan de Oro City.
2. Separate charges were filed against him for each item; the case for the replica firearm was dismissed due to insufficient allegations.
3. January 27, 2016: The RTC convicted Olarte for illegal possession of the grenade.
4. April 6, 2017: The CA affirmed the RTC’s decision.
5. Olarte appealed to the Supreme Court, questioning the legality of his arrest and the conviction.
Petitions and Motions:
– Olarte filed an appeal contesting his warrantless arrest and the admissibility of the grenade seized during the arrest.
– The prosecution moved to amend the original information regarding the grenade’s fuse assembly marking, which was granted by the RTC.
### **Issues:**
1. Whether the warrantless arrest of Olarte was valid, including the admissibility of the grenade as evidence.
2. Whether the prosecution could validly amend the information to correct the grenade’s fuse assembly marking.
3. Whether the identity and integrity of the corpus delicti (the grenade) were compromised, casting doubt on Olarte’s guilt.
### **Court’s Decision:**
1. **Valid Warrantless Arrest:** The SC upheld the validity of Olarte’s arrest as he was caught in the act of committing an offense, validating the incidental search and seizure.
2. **Validity of Amended Information:** The amendment to the information was deemed a formal amendment that did not prejudice Olarte’s rights, nor did it change the nature of the accusation. The change from “M204X2” to “M204A2” was a correction of a clerical error and thus permissible.
3. **Identity and Integrity of Corpus Delicti:** The SC concluded that the integrity and evidentiary value of the grenade had been sufficiently maintained throughout the handling and custody chain, dismissing Olarte’s contention regarding the grenade’s identification markings.
### **Doctrine:**
The decision reiterated doctrines regarding warrantless arrests, specifically that an individual may be arrested without a warrant if caught committing, attempting to commit, or has just committed an offense. It also underscored that formal amendments to legal information, which do not prejudice the accused’s rights nor alter the case’s essence, are permissible even after the accused has pleaded.
### **Class Notes:**
– **Warrantless Arrests**: Permissible under specific conditions outlined in the Rules of Court, including when an individual is caught in the act of committing an offense.
– **Amendments to Information**: Amendments to the charge or information in a criminal case can be substantial or formal. Formal amendments that do not change the nature of the charge or prejudice the defendant’s defense are allowable.
– **Corpus Delicti**: Refers to the actual body or substance of the crime. In illegal possession cases, it involves proving the existence of the prohibited item and the accused’s lack of legal authority to possess the same.
### **Historical Background:**
This case further illuminates the Philippine legal system’s balance between enforcing law and order and protecting individual rights, especially concerning warrantless arrests and handling of evidence, against the backdrop of ensuring public safety and upholding justice.
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