Agravante v. People

Summary

Ian Agravante was charged with illegal possession of firearms and ammunition under PD 1866 after police found improvised gun and ammunition in his possession during a search following theft report. RTC and CA convicted him, finding valid warrantless arrest and search. Supreme Court reversed, ruling the warrantless arrest invalid due to lack of personal knowledge by arresting officers and absence of immediacy element - 11 hours elapsed between crime report and arrest, allowing time for proper warrant procurement. Police relied on witness tip without personal observation of crime. Search incidental to unlawful arrest violated constitutional protections against unreasonable search and seizure. Evidence obtained declared inadmissible under exclusionary rule, resulting in acquittal. Case establishes strict requirements for warrantless arrests under Section 5(b), Rule 113, emphasizing personal knowledge and immediacy elements.