PEOPLE v. NOEL ENOJAS Y HINGPIT

FACTS:

On the evening of August 29, 2006, police officer PO2 Francisco Pangilinan and PO2 Eduardo Gregorio encountered a suspiciously parked taxi while patrolling the area near the intersection of BF Almanza and Alabang-Zapote Roads in Las Piñas. The officers approached the taxi and asked the driver for his documents, later identified as accused Noel Enojas. They requested Enojas to accompany them to the police station for further questioning, and Enojas voluntarily complied, leaving his taxi behind.

While on their way to the police station, the officers stopped at a 7-11 store. PO2 Pangilinan entered the store to relieve himself but encountered two suspected robbers. A shootout ensued between PO2 Pangilinan and the suspects, resulting in the death of one suspect and the injury of the other. However, PO2 Pangilinan was shot by someone else at the scene, causing his death.

PO2 Gregorio arrived at the scene and fired at an armed man who was attempting to flee. Another individual fired at PO2 Gregorio before escaping in a taxi. Subsequently, it was discovered that Enojas, the taxi driver, had fled as well. The police initiated an investigation and ultimately apprehended the other accused based on text messages they monitored on Enojas' mobile phone.

The accused were later found guilty of murder by the Regional Trial Court, a decision which was affirmed by the Court of Appeals. The defense argued that their arrests were illegal and that the text messages obtained from Enojas' mobile phone were inadmissible as evidence.

ISSUES:

  1. Whether the accused were illegally arrested.

  2. Whether the evidence of the text messages between the accused were admissible.

RULING:

  1. The accused were not illegally arrested. The police officers approached the taxi and asked the driver for his documents. When they entertained doubts regarding the veracity of the documents, they asked the driver to come with them to the police station for further questioning. The driver voluntarily went with the officers. Therefore, the arrest was lawful.

  2. The evidence of the text messages between the accused was admissible. The police officers monitored the messages in the mobile phone left behind by the driver. They posed as the driver and communicated with the other accused. This evidence was obtained through a valid entrapment operation and was admissible in court.

PRINCIPLES:

  • Lawful arrest: A warrantless arrest is valid if it is made after the commission of an offense, the arresting officer has personal knowledge of facts indicating that the person to be arrested has committed the offense, and the person to be arrested is either in flagrante delicto or has just committed an offense.

  • Admissibility of evidence: Evidence obtained through a valid entrapment operation is admissible in court.