FACTS:

Marvin, a 22-year-old college student, was charged with stealing a necklace worth P10,000 from a department store without the owner's consent. The incident was captured on CCTV, showing Marvin taking the necklace and leaving the store without paying. Store employees reported the incident to the security personnel who apprehended Marvin and brought him to the police station. During police questioning, Marvin admitted to stealing the necklace, citing financial difficulties with his college expenses. Marvin was charged and a trial was conducted to determine his guilt or innocence.

ISSUES:

1. Whether the arrest of Marvin was valid based on the information received regarding a suspicious person.

2. Whether the objection to the validity of arrest is waived.

3. Whether the OR and CR allegedly found in Marvin's possession are admissible as evidence.

4. Whether the search of Marvin's body and belongings is valid as a stop-and-frisk search.

5. Whether Marvin's alleged admissions of guilt are admissible as evidence.

6. Whether Marvin's statements regarding the possession of the motorcycle and the discovery of the gun can be considered as admissible evidence.

7. Whether Marvin's confession to Virgie is admissible as evidence.

8. Whether the extrajudicial confession of the petitioner is admissible as evidence against him.

9. Whether the circumstantial evidence sufficiently corroborates the extrajudicial confession.

10. Whether or not the notice of appeal filed by the petitioner complies with the requirement of indicating the subject matter of the appeal.

11. Whether or not the petitioner's appeal filed before the Court of Appeals (CA) was filed out of time.

RULING:

1. The arrest of Marvin was not valid. The prosecution failed to establish that Marvin committed a crime, was committing, or was about to commit a crime in the presence of the arresting officers. The mere suspicion that a crime was committed is not enough to justify the arrest. The anonymous report of a suspicious person does not vest personal knowledge on the police officers about the commission of an offense. The arrest could not be justified as an in flagrante delicto arrest as Marvin was not exhibiting any unusual conduct that would incite suspicion. Furthermore, the law enforcers had no personal knowledge of any fact or circumstance indicating that Marvin had just committed an offense. Thus, the warrantless arrest was deemed illegal.

2. The objection to the validity of arrest is deemed waived because Marvin participated in the proceedings before the trial court. However, this does not preclude the Court from ruling against the admissibility of the evidence obtained from the illegal warrantless arrest.

3. The OR and CR allegedly found in Marvin's possession after his arrest are inadmissible as evidence. The Court cannot consider these documents as part of the prosecution's circumstantial evidence.

4. The search of Marvin's body and belongings is not valid as a stop-and-frisk search. The search cannot be justified based on a suspicion or a hunch. There was no genuine reason for the police officer to stop and frisk Marvin.

5. Marvin's alleged admissions of guilt are inadmissible as evidence because they were obtained in violation of his rights to remain silent and to counsel. Confessions or admissions obtained in violation of these rights are inadmissible.

6. The statements made by Marvin regarding the possession of the motorcycle and the discovery of the gun are inadmissible as evidence. Marvin was already under custodial investigation at the time he made these statements, and his right to counsel automatically attached. Since there is no evidence that Marvin was informed of his rights or granted the opportunity to obtain counsel, his statements cannot be considered as voluntary and admissible evidence.

7. The confession made by Marvin to Virgie is not admissible as evidence. While the confession to a private party is not subject to the constitutional and statutory limitations on extrajudicial confessions, the voluntariness of the confession must still be established. In this case, the confession was not reduced into writing or recorded in any manner, and there is no independent evidence to establish its voluntariness and substance. Virgie's testimony can only be admitted as an independently relevant statement, which proves only the fact that such statement was made. It is not sufficient proof of its veracity.

8. The extrajudicial confession of the petitioner is not admissible as evidence against him. An extrajudicial confession is not a sufficient ground for conviction and must be corroborated by either direct or circumstantial evidence. In this case, the circumstances raise doubts as to the voluntariness and veracity of the alleged confession. The Court cannot determine the voluntariness and veracity of the oral confession made to a certain Virgie.

9. The circumstantial evidence does not sufficiently corroborate the extrajudicial confession. Most of the circumstantial pieces of evidence are inadmissible as evidence against the petitioner. The only remaining circumstance, the recovery of the stolen motorcycle, does not connect the petitioner to the crime. The police officers did not recover the motorcycle through the information provided by the petitioner. The doubts as to the guilt of the petitioner are more than reasonable, warranting his acquittal.

10. The Supreme Court held that the notice of appeal filed by the petitioner did not comply with the requirement of indicating the subject matter of the appeal. The Court ruled that the subject matter is an essential requirement for validly perfecting an appeal. Therefore, the petitioner's appeal was considered not properly initiated.

11. The Supreme Court ruled that the petitioner's appeal before the CA was filed out of time. The Court held that the petitioner failed to file the notice of appeal within the reglementary period as prescribed by the Rules of Court. As a result, the CA correctly dismissed the petitioner's appeal for being filed out of time.

PRINCIPLES:

• A mere suspicion that a crime was committed is not enough to justify an arrest. There must be personal knowledge of facts indicating that the person sought to be arrested has just committed a crime, was committing, or is about to commit a crime.

• Anonymous reports or tips do not justify a warrantless arrest. The law enforcers must have personal knowledge of facts based on their observation.

• The search conducted on a person's body and belongings must be preceded by a lawful arrest. A search cannot validate an illegal arrest.

• If there is an irregularity in the arrest, the accused must object to its validity before arraignment. Otherwise, the objection is deemed waived.

• The waiver of an illegal warrantless arrest does not make the evidence seized during the illegal arrest admissible.

• Objection to the validity of arrest can be waived if the accused participates in the proceedings before the trial court.

• Evidence obtained from an illegal warrantless arrest is inadmissible.

• Stop-and-frisk search is limited to the protective search of outer clothing for weapons and must be based on a genuine reason supported by manifest overt acts of the accused.

• Confessions or admissions made in violation of the accused's right to remain silent and right to counsel are inadmissible as evidence.

• When a person is under custodial investigation, his right to counsel automatically attaches, and any statements made during the investigation without the presence of counsel are inadmissible as evidence unless there is a valid waiver of this right. (Miranda Doctrine)

• A confession must be made freely, without inducement, and with full awareness of its consequences to be admissible as evidence. (Voluntariness of Confession)

• An extrajudicial confession forms but a prima facie case against the party by whom it is made and is not conclusive proof. It may be proved that the confession was uttered in ignorance, levity, or mistake. It is regarded as only cumulative proof that affords a precarious support and on which a verdict cannot be permitted to rest.

• An extrajudicial confession is not a sufficient ground for conviction and must be corroborated by either direct or circumstantial evidence. If circumstantial evidence is relied upon, there must be more than one circumstance, the facts must be proven, and the combination of all the circumstances must produce a conviction beyond reasonable doubt.

• The subject matter is an essential requirement for a valid notice of appeal.

• Failure to file the notice of appeal within the reglementary period will result in the dismissal of the appeal for being filed out of time.