People v. Mengote

Summary

Rogelio Mengote was convicted of illegal possession of firearms under P.D. 1866 after police seized a .38 caliber revolver during a warrantless arrest. The Supreme Court reversed his conviction, ruling that the arrest was unconstitutional. Officers arrested Mengote based solely on anonymous tip and his 'suspicious' behavior of looking around and holding his abdomen in broad daylight on a busy street. The Court held this did not constitute probable cause under Rule 113, Section 5, as no offense was being committed in their presence and officers lacked personal knowledge of any crime. The seized firearm, being fruit of an illegal arrest, was inadmissible under the constitutional exclusionary rule. This landmark decision reinforced Fourth Amendment protections against unreasonable searches and seizures, emphasizing that mere suspicion cannot justify warrantless arrests in a free society.