Case No.

1313
PADILLA v. COURT OF APPEALS
G.R. No. 121917
March 12, 1997
FACTS OF THE CASE
During a rainy day, petitioner herein, driving a Mitsubishi Pajero with plate number PMA-777 was involved
in a hit-and-run incident along McArthur Highway in Angeles City. The witnesses of the incident reported
the same to the police authorities. Consequently, police officers near the vicinity of the incident were
alerted. Mobile patrol vehicles were also mobilized in order to five chase to petitioner. The chase ended at
the Abarcan Bridge where petitioner was flagged down and was apprehended by police officers. When
petitioner was arrested, the police were able to confiscate a gun with six (6) live bullets from petitioner.
Also, the vehicle contained a baby armalite rifle also containing live bullets. On the other hand, petitioner
argued that the gun was covered with the required legal papers. The police authorities then invited petitioner
to the police station for proper investigation and questioning. Inside the police station, petitioner admitted
to the possession of the same firearms. However, petitioner was not able to produce to required papers for
the same.
As a result, an information was filed before the RTC of Angeles City against petitioner charging the latter
with illegal possession of firearms and ammunition under P.D. 1866. The RTC, accordingly, rendered its
decision, finding petitioner guilty beyond reasonable doubt of the crime charged. Subsequently, petitioner
applied for bail in the amount of P200,000.00.
ISSUE/S
Whether or not the warrantless search and subsequent warrantless arrest of petitioner renders the evidence
obtained inadmissible
HELD/RATIO
In the case at bar, the Court considered the arrest as a hot pursuit arrest wherein petitioner evaded criminal
liability in the event of the hit-and-run incident as reported to the police. Consequently, the Court considered
the warrantless search as a search incidental to lawful arrest. The Court further held that petitioner was
caught in flagrante delicto as he was found to be in possession of illegal firearms. More importantly, the
filing of the bail bond by the petitioner constituted a waiver of an appeal against the alleged irregularities
and defects of the search and arrest.

Prepared by: Antonio Dominic G. Salvador