- Petitioner
- Santiago
- Respondent
- People
- Citation
- G.R. No. 238670
- Court
- Supreme Court
- Division
- First Division
- Decided
- July 11, 2018
Summary
Joseph Santiago was convicted of illegal possession of firearms under RA 10591 after being arrested in a warrantless arrest based on a police report. Officers found him with an unlicensed paltik revolver and ammunition at Villalobos corner Carlos Palanca Streets, Manila. The trial court convicted him, which was affirmed by the Court of Appeals. The Supreme Court denied his petition for review, ruling that he raised factual issues inappropriate for a Rule 45 petition, that his warrantless arrest was valid based on reasonable suspicion, and that he waived objections to the arrest by not filing a motion to quash. The Court affirmed his guilt but modified the penalty under the Indeterminate Sentence Law to 9 years and 4 months to 11 years and 4 months imprisonment. The case demonstrates the application of firearms laws and criminal procedure rules in warrantless arrest situations.